BlueCrest Capital v HMRC

What if a partner of limited partnership A with no legal personality becomes a partner of limited partnership B in its capacity as the general partner of partnership A: are the limited partners in partnership A partners of partnership B?

If not is the general partner taxed on the profit allocation from partnership B even though it must allocate it to the partners of partnership A?

When the partner borrows to acquire an interest in the partnership are they borrowing to acquire an interest in the partnership trade?

These are the questions considered by the Court of Appeal in BCM Cayman LP and BlueCrest Capital Management Cayman Limited v CRC [2023] EWCA Civ 1179.

They are also the type of questions that can make your head hurt.

The facts

BlueCrest Capital Management LP (UK LP) was a fund manager carrying on a trade of investment...