The Boston Consulting Group UK LLP and others v HMRC

In The Boston Consulting Group UK LLP and others v HMRC [2024] UKFTT 84 (TC) (23 January 2024) the First-tier Tribunal (FTT) found that payments made to individual members of a UK LLP on ‘sales’ of their ‘capital interests’ were taxable as income under the miscellaneous category in ITTOIA 2005 s 687.

The appellants were individual partners in a management consulting firm which conducted business in the UK through a UK LPP together with that LLP. The main issue in this case was the correct tax treatment of payments received by those individuals on the disposal of certain interests they held in the LLP called ‘capital interests’. Capital interests were allocated to partners in the firm and their value increased or decreased based on the group’s global performance. Pursuant to the limited partnership agreement an individual would be required to sell their interests to the...

If you are not a subscriber, subscribe now to read this content.

If you are already a subscriber, sign in

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.

Once you have registered, you will receive an email directing you back to read this article in full.