The case revolved around the partners of the limited liability partnership (LLP), Bluecrest Capital, owned by billionaire Michael Platt and had been through the First Tier and Upper tribunals before the Court of Appeal sent it back to the FTT this week, saying both tribunals had erred in law by not interpreting Condition A and Condition B of the disguised remuneration rules correctly.

Judge Sir Launcelot Henderson ruled that ‘for the avoidance of doubt, that Condition A is met in relation to all relevant individual members of the LLP, including the portfolio managers and the desk heads who managed $3.9bn in assets in 2022.

He also allowed HMRC’s appeal on Condition B, accepting the tax authority’s ‘alternative argument (formulated during the hearing) on its true construction’.

HMRC