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 – deferred remuneration tax whereby amounts reallocated pursuant to discretion decision to individual LLP members via corporate LLP member – whether amounts were partnership profits under s850 ITTOIA 2005 as HMRC argued – no (applying BlueCrest UT) - whether amounts taxable as miscellaneous income under s687 ITTOIA 2005 - yes – whether finding on discovery made – yes – FTT’s refusal of appellants’ application for redaction under Rule 14 UT Rules upheld –HMRC’s and appellants’ appeals dismissed
Published 21 March 2023