[2026] UKUT 00025 (TCC) HMRC v The Boston Consulting Group UK LLP and others Holden v HMRC
Upper Tribunal Tax and Chancery Decision of Mr Justice Thompsell and Judge Redston on 20 January 2026
Read full decision:
INCOME TAX AND CAPITAL GAINS TAX – Limited Liability Partnership - whether amounts identified as “capital interests” were income or capital – if income, whether within Condition X and/or Condition Y of the mixed member partnership rules at ITTOIA s 850C –whether miscellaneous income under ITTOIA s 687 – if capital, whether within the occupational income rules – various procedural issues including considering the meaning and application of the statutory phrase ”on behalf of“ together with the requirement that carelessness cause the loss of tax
Updates to this page
Published 20 January 2026