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First-tier Tribunal (Tax)
You are here: BAILII >> Databases >> First-tier Tribunal (Tax) >> BLUECREST CAPITAL MANAGEMENT (UK) LLP v Revenue & Customs (PAYE and NICs - salaried members legislation in sections 863A-G ITTOIA 2005 and section 4A SSCBA 1992) [2022] UKFTT 204 (TC) (29 June 2022)
URL: http://www.bailii.org/uk/cases/UKFTT/TC/2022/TC08529.html
Cite as: [2022] UKFTT 204 (TC), [2022] STI 992, [2022] SFTD 1201
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| Decision Number: | TC 08529 |
| Appellant: | BLUECREST CAPITAL MANAGEMENT (UK) LLP |
| Respondent: | Her Majesty's Revenue & Customs |
|
Chairmen / Special Commissioners: |
Nigel POPPLEWELL |
| Date Of Decision: | 29/06/2022 |
| Main Category: | PROCEDURE |
| Main Subcategory: | Other |
| Notes: | PAYE and NICs - salaried members legislation in sections 863A-G ITTOIA 2005 and section 4A SSCBA 1992- application to members of a hedge fund manager trading as an LLP - Condition A - were the bonuses variable without reference to the profits of the LLP?- yes - Condition A met for all members - Condition B - did the members have significant influence over the affairs of the LLP? - yes for the traders with capital allocations of $100 million or more - no for the other members - appeal allowed in part |