The Supreme Court has today released its judgment in this case, which concerns the salaried members legislation (sections 863A to 863G ITTOIA 2005) and in particular Conditions A (disguised salary) and B (significant influence).
The Court dismissed BlueCrest’s appeal in relation to both Conditions. The application of Condition B has been remitted to the FTT.
Richard Vallat KC and Laura Poots KC, together with James Kirby, acted for HMRC.
Barbara Belgrano, together with Hui Ling McCarthy KC, John Machell KC and Jennifer Haywood, acted for BlueCrest.
You can read a copy of the judgment here.
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