HMRC’s guidance on the new salaried member rules for LLPs creates nearly as much uncertainty as it dispels. The ‘Working Wheels’ scheme, which saw taxpayers seeking to deduct a £5m fee for borrowing £7,500, is given short shrift by the FTT. Some taxpayer wins outside the marketed scheme arena underline the neutrality of the purposive construction principle and indicate that HMRC cannot always have its cake and eat it.
