The Supreme Court has handed down its judgment in HMRC v BlueCrest Capital Management (UK) LLP, dismissing BlueCrest’s appeal and providing important clarification on the application of the salaried members rules to investment management LLPs.
The decision is particularly significant for asset managers, hedge fund managers and other investment management businesses operating through LLPs. Many such businesses have members who are economically important to the firm, make substantial investment decisions and may be responsible for significant profits. The Supreme Court has confirmed, however, that this will not necessarily mean those members have “significant influence” for the purposes of the salaried members rules.
In broad terms, the Court confirmed that influence must be grounded in the member’s legally enforceable rights and duties as a member of the LLP. Informal or de facto influence arising from a member’s performance, commercial importance, client relationships or investment… Read the complete article here...
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