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SALARIED-MEMBERS


The application of Ramsay in a recent case and HMRC’s revised guidance on salaried members are among the topics covered in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).
This month’s review by Mike Lane and Zoe Andrews (Slaughter and May) covers the decisions in Lloyds Asset Leasing and Royal Bank of Canada, as well as HMRC’s plans to update guidance on the salaried member rules.
HMRC permission to appeal against case management decisions refused
David Haworth and David Haughey (Freshfields) examine the implications of the Court of Appeal’s decision for businesses which are potentially within the scope of the UK’s salaried member rules.
Court of Appeal remits salaried members case to FTT.
LLPs would be well advised to consider the status of their members in light of recent developments, writes Jitendra Patel (BDO).
Emily Clark and Ian Zeider (Travers Smith) revisit the Upper Tribunal’s salaried members judgment in BlueCrest, focusing on what it means for LLPs. Is there now more scope to claim ‘significant influence’, but perhaps less certainty of being on the right side of the line?

The BlueCrest salaried members case, three HMRC victories on SDLT and three recent taxpayer wins on penalties. Edward Reed and Thomas Schlee (Macfarlanes) review recent developments in the private client world.

Amanda Hardy KC and Oliver Marre (5 Stone Buildings) examine the first Upper Tribunal judgment on the meaning of ‘significant influence’.
The result of the BlueCrest appeal represents a good outcome for many businesses structured as LLPs, write Amanda Hardy QC and Oliver Marre (5 Stone Buildings). 
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