Article
Supreme Court Decides The LLP Salaried Member Rules - But Sends BlueCrest Back To The First-Tier Tax Tribunal
The Supreme Court has delivered its landmark decision in HMRC v BlueCrest Capital Management, clarifying the salaried member rules that determine whether LLP members are taxed as employees or partners. The ruling refines the legal test for "significant influence" and establishes that influence must derive from enforceable governance frameworks rather than informal practice, with immediate implications for how LLPs structure membership terms and delegated authority.
Macfarlanes LLP