BlueCrest Capital Management (UK) LLP v HM Revenue and Customs

Tuesday 26 - Wednesday 27 November 2024
Before Lord Justice Lewison
Lord Justice Arnold
Sir Launcelot Henderson
Both parties appeal the decision, dated 18 September 2023 of the Upper Tribunal (Tax and Chancery Chamber) upholding the First Tier Tribunal’s decision that Condition B relating to the application of the salaried members rules contained in sections 863A-863G Income Tax (Trading and other Income) Act 2005 (“ITTOIA”) did not apply to individual members of BlueCrest who acted as portfolio managers of desk heads.
The dispute concerns the application of the salaried members legislation to certain individual members of BlueCrest, which is a hedge fund manager trading as an LLP.