Over the past three years the first tax case regarding the salaried members’ legislation (BlueCrest) has been working its way through the courts providing many plot twists for limited liability partnerships (LLPs) and advisers. The latest judgment was released by the Court of Appeal in January 2025 and a permission to appeal application has since been lodged with the Supreme Court.
This case has important implications for businesses operating through a UK LLP and much has been written on each court’s judgment. This article seeks to summarise the key points alongside providing an update on HMRC’s guidance on an aspect of these rules.
Purpose and recap of the rules
The salaried member rules were introduced in 2014 to remove the presumption that a UK LLP member is taxed as a self-employed individual for UK tax purposes. These rules seek to counteract arrangements where LLP...
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