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Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.
Article
BlueCrest: Supreme Court Confirms Narrow Interpretation Of “Significant Influence” Exclusion From Salaried Members Rules
The UK Supreme Court has delivered a landmark ruling on the "salaried members rules" for Limited Liability Partnerships, significantly narrowing the interpretation of when members can claim "significant influence" to avoid employee tax treatment. The decision confirms that influence must derive from legal rights in the LLP agreement and be exercised at a strategic level over the partnership's affairs generally, rather than through operational roles or financial importance.
United Kingdom Tax
TS
Travers Smith LLP
Article
Bluecrest - UK Supreme Court Confirms Interpretation Of The LLP Salaried Member Rules
The UK Supreme Court has delivered its judgment in HMRC v Bluecrest Capital Management (UK) LLP, addressing critical questions about when LLP members should be treated as self-employed versus employees for tax purposes. The ruling clarifies the interpretation of "disguised salary" and "significant influence" tests, establishing that influence must derive from legally enforceable rights rather than informal commercial importance.
United Kingdom Tax
D
Dechert
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Corporate Tax

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Withholding Tax

Article
Co-Investment In Private Credit: Structuring And Fee Considerations For Sponsors
Private credit co-investment has evolved from a relationship benefit to a core product feature, driven by investor demand for enhanced returns, portfolio control, and stronger sponsor relationships. This article examines five structural alternatives for credit co-investment programs, analyzing how sponsors can optimize their approach based on execution certainty, regulatory considerations, and investor requirements.
United Kingdom Finance
M
Macfarlanes LLP
Article
When Is A Day Not A Day? UK Tax Residence And The Statutory Residence Test
The UK determines tax residence based on the Statutory Residence Test (SRT). While the rules can be complex, incorporating five Automatic Overseas Tests, four Automatic UK Tests, eight potential split year cases, and the sufficient ties test (with five possible ties), in many cases the outcome ultimately turns on a simple metric: the number of days spent in the UK.
United Kingdom Commercial
DG
Dixcart Group Limited
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Tax Treaties

Article
European Commission's Tax Simplification Package And The Future Of The Unshell Substance Tests
The European Commission has adopted a tax simplification package that abolishes withholding taxes on cross-border payments and modernises key direct tax directives. For private capital managers, the most significant development may be the formal withdrawal of the controversial Unshell Directive, though substance requirements remain on the regulatory agenda in a different form.
United Kingdom Tax
M
Macfarlanes LLP
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Income Tax

Article
BlueCrest: Supreme Court Confirms Narrow Interpretation Of “Significant Influence” Exclusion From Salaried Members Rules
The UK Supreme Court has delivered a landmark ruling on the "salaried members rules" for Limited Liability Partnerships, significantly narrowing the interpretation of when members can claim "significant influence" to avoid employee tax treatment. The decision confirms that influence must derive from legal rights in the LLP agreement and be exercised at a strategic level over the partnership's affairs generally, rather than through operational roles or financial importance.
United Kingdom Tax
TS
Travers Smith LLP
Article
Bluecrest - UK Supreme Court Confirms Interpretation Of The LLP Salaried Member Rules
The UK Supreme Court has delivered its judgment in HMRC v Bluecrest Capital Management (UK) LLP, addressing critical questions about when LLP members should be treated as self-employed versus employees for tax purposes. The ruling clarifies the interpretation of "disguised salary" and "significant influence" tests, establishing that influence must derive from legally enforceable rights rather than informal commercial importance.
United Kingdom Tax
D
Dechert
See more

Tax Authorities

Article
Bluecrest - UK Supreme Court Confirms Interpretation Of The LLP Salaried Member Rules
The UK Supreme Court has delivered its judgment in HMRC v Bluecrest Capital Management (UK) LLP, addressing critical questions about when LLP members should be treated as self-employed versus employees for tax purposes. The ruling clarifies the interpretation of "disguised salary" and "significant influence" tests, establishing that influence must derive from legally enforceable rights rather than informal commercial importance.
United Kingdom Tax
D
Dechert
See more

Latest Videos

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