The CIOT has provided an update on the LLP salaried member rules and HMRC’s compliance approach following BlueCrest.
The CIOT update outlines HMRC’s approach to managing open compliance checks in relation to the Salaried Member Rules (SMR) following the Court of Appeal’s decision in BlueCrest [2025] EWCA Civ 23 with further developments pending an application for permission to appeal to the Supreme Court.
HMRC have indicated in their correspondence to Limited Liability Partnerships (LLPs) that they remain duty bound to apply the law in accordance with their Litigation and Settlement Strategy (LSS). In light of the ruling that ‘significant influence over the affairs of the partnership’ contemplated by ITTOIA 2005 s 863C Condition B must derive solely from the mutual rights and duties set out in the statutory and contractual framework that governs the operation of the LLP HMRC’s compliance work in relation to Condition B of...
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The CIOT has provided an update on the LLP salaried member rules and HMRC’s compliance approach following BlueCrest.
The CIOT update outlines HMRC’s approach to managing open compliance checks in relation to the Salaried Member Rules (SMR) following the Court of Appeal’s decision in BlueCrest [2025] EWCA Civ 23 with further developments pending an application for permission to appeal to the Supreme Court.
HMRC have indicated in their correspondence to Limited Liability Partnerships (LLPs) that they remain duty bound to apply the law in accordance with their Litigation and Settlement Strategy (LSS). In light of the ruling that ‘significant influence over the affairs of the partnership’ contemplated by ITTOIA 2005 s 863C Condition B must derive solely from the mutual rights and duties set out in the statutory and contractual framework that governs the operation of the LLP HMRC’s compliance work in relation to Condition B of...
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