Bluecrest Capital Management (UK) Llp v Revenue and Customs: FTTTx 29 Jun 2022

PAYE and NICs – salaried members legislation in sections 863A-G ITTOIA 2005 and section 4A SSCBA 1992- application to members of a hedge fund manager trading as an LLP – Condition A – were the bonuses variable without reference to the profits of the LLP?- yes – Condition A met for all members – Condition B – did the members have significant influence over the affairs of the LLP? – yes for the traders with capital allocations of $100 million or more – no for the other members – appeal allowed in part


[2022] UKFTT 204 (TC)




England and Wales

Income Tax

Updated: 31 July 2022; Ref: scu.679641