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.
To view the decision, click here.