Emily Clark (Head of Asset Management) and Ian Zeider (Knowledge Counsel) have recently co-authored a Tax Journal article on the Upper Tribunal's decision in HMRC v BlueCrest Capital Management (UK) LLP relating to the application of the salaried members rules. In its decision, the Tribunal rejected HMRC’s restrictive interpretation of the exclusions from salaried member status. In particular, it confirmed that ‘significant influence’ is not limited to managerial influence over all the affairs of the LLP’s business.
Read our original briefing on the decision.
This article was first published in Tax Journal, 3 November 2023
