In an appeal to the Upper Tribunal, Charles Tyrwhitt LLP, a retailer of shirts and other items of clothing, which operates as a limited liability partnership (LLP) appealed the decision by the First Tier Tribunal which was released on 21 June 2020.

LLPs were created by the Limited Liability Partnerships Act 2003 and are taxed in the same way as traditional partnerships. Unlike traditional partnerships, their members have limited liability for the debts of the partnership, and, in consequence, the partnership has a legal personality as a corporation in its own right.