The Upper Tribunal ruled against the appellants, HFFX LLP and its managing member Alexander Gerko, involving the tax treatment of a deferred remuneration arrangement known as the Capital Allocation Plan (CAP).

HFFX LLP appealed against amendments and discovery assessments totalling £22.5m issued by HMRC to its partnership returns.

In addition, a further issue concerning one of the discovery assessments made in respect of Alexander Gerko for the years 2012/13 was also heard.