HFFX LLP, Christopher Shucksmith and others v The Commissioners for HM Revenue and Customs [2023] UKUT 00073 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Mellor and Judge Swami Raghavan on 20 March 2023
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INCOME TAX 鈥� deferred remuneration tax whereby amounts reallocated pursuant to discretion decision to individual LLP members via corporate LLP member 鈥� whether amounts were partnership profits under s850 ITTOIA 2005 as HMRC argued 鈥� no (applying BlueCrest UT) - whether amounts taxable as miscellaneous income under s687 ITTOIA 2005 - yes 鈥� whether finding on discovery made 鈥� yes 鈥� FTT鈥檚 refusal of appellants鈥� application for redaction under Rule 14 UT Rules upheld 鈥揌MRC鈥檚 and appellants鈥� appeals dismissed
Updates to this page
Published 21 March 2023