The decision at the Supreme Court means the members of HFFX LLP, a limited liability partnership (LLP) led by principal member and billionaire forex trader Alexander Gerko, should have paid income tax on their profit allocations rather than using a complex structure involving corporation tax on profits through a corporate member of the LLP.

HFFX LLP was established in 2010 within a pre-existing investment management business known as GSA, and had 12 other individual LLP members. These members designed and implemented software used by GSA funds for high-frequency foreign exchange trading.