29 June 2022
BlueCrest Capital Management LLP v HMRC; (FTT)
The First-tier Tribunal has released its decision in BlueCrest Capital Management (UK) LLP v HMRC. This is the first case to consider the application of the salaried members legislation in sections 863A-G ITTOIA 2005.
The Tribunal was asked to consider the application of Conditions A (disguised salary) and B (significant influence) to members of an LLP carrying out investment management activities and providing back office services to other entities within the BlueCrest group. The Tribunal concluded that Condition A was met in relation to all members, but that Condition B was only met for certain categories of members, and so the appeal was allowed in part.
Richard Vallat QC, Laura Poots and Calypso Blaj appeared for HMRC.
To view the decision, click here.
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