United Kingdom: Income Tax

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Article
Royalties On The Rails: Distinguishing Trust Capital And Income For Tax Purposes
Finally, the court considered the case of PL Travers Will Trust v HMRC [2014] SFTD 265, which concerned the tax treatment of royalty payments under the will of PL Travers, author of the Mary Poppins series. This had found that part of the receipts from the author’s copyrights had been income but only in relation to a specific period in which the trustees had been responsible for the exploitation of the copyright. This was not the case here.
United Kingdom Tax
S
Stewarts
Article
Mandatory Payrolling Of Benefits In Kind: What Employers Need To Know
From April 2027, HMRC will begin mandatory payrolling of benefits in kind, moving away from the current system of year-end reporting towards real-time deductions through payroll. HMRC has confirmed a two-phased approach: only selected benefits will be subject to mandatory payrolling from April 2027, with full payrolling expected from April 2028 (subject to certain exclusions discussed below).
United Kingdom Tax
LS
Lewis Silkin
Article
Section 431 Elections – What Are They And What Are The Tax Benefits?
When employers grant restricted securities to employees, understanding section 431 elections can significantly impact tax liabilities for both parties. This article examines how these elections work, the strict 14-day filing deadline, and demonstrates through detailed calculations why choosing to make this election could save substantial amounts in income tax and national insurance contributions.
United Kingdom Tax
Sa
Shepherd and Wedderburn LLP
Article
HMRC V BlueCrest: Supreme Court Confirms Narrower Approach To Condition B
The Supreme Court's landmark decision in HMRC v BlueCrest Capital Management establishes crucial guidance on when LLP members should be taxed as employees rather than partners, focusing on legally conferred governance powers over commercial influence. This ruling will fundamentally reshape how professional services firms, investment managers, and businesses structure their LLP arrangements and assess member status under the salaried members rules.
United Kingdom Tax
K
Kennedys
Article
BlueCrest: UK Supreme Court Clarifies “significant Influence” Under The LLP Salaried Members Rules
The Supreme Court has clarified the application of the salaried members rules to investment management LLPs in HMRC v BlueCrest Capital Management, establishing that significant influence must be grounded in legally enforceable rights rather than commercial importance or investment responsibilities. The decision narrows the scope for portfolio managers and desk heads to rely on Condition B, requiring investment management LLPs to review their governance arrangements and member classifications.
United Kingdom Tax
PR
Proskauer Rose LLP
Article
Supreme Court Decides The LLP Salaried Member Rules - But Sends BlueCrest Back To The First-Tier Tax Tribunal
The Supreme Court has delivered its landmark decision in HMRC v BlueCrest Capital Management, clarifying the salaried member rules that determine whether LLP members are taxed as employees or partners. The ruling refines the legal test for "significant influence" and establishes that influence must derive from enforceable governance frameworks rather than informal practice, with immediate implications for how LLPs structure membership terms and delegated authority.
United Kingdom Tax
M
Macfarlanes LLP
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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