Amanda Hardy and Oliver Marre write on BlueCrest tax appeal for Tax Journal

Amanda Hardy QC and Oliver Marre have written an article about the BlueCrest salaried members tax appeal for the latest edition of Tax Journal.

Amanda and Oliver represented the appellant hedge fund in the appeal, which was the first case on the salaried members LLP tax rules.

The First-Tier tribunal held that the vast majority of BlueCrest’s portfolio managers had “significant influence” over the affairs of the LLP and had therefore correctly been treated as partners by the LLP for income tax and national insurance purposes.

The article is available here.

The judgment of the FTT is available here.