The LLP Salaried Members Rules: Compliance After Bluecrest

Introduction

Following the Supreme Court’s decision in the Bluecrest salaried members case, there is now much greater clarity on how the salaried members’ rules should be applied. The judgment is likely to shape HMRC’s compliance activity for years to come, with HMRC already taking an increasingly robust approach in this area. For example, in BGC Services Holdings LLP, HMRC issued a £96 million determination without providing any reasons.

Against this backdrop, understanding how the rules apply in practice has never been more important. This live virtual classroom seminar provides both a comprehensive refresher and a practical analysis of the key compliance issues, recent case law and HMRC’s approach. Aimed at accountants, legal and tax advisers, this session will help you apply the rules with confidence, minimise the risk of challenge and advise clients in light of the Supreme Court’s decision.

What You Will Learn

This live and interactive session will cover the following:

• A review of the three statutory conditions that determine whether LLP members are taxed as employed or self-employed - and why the distinction is critical
• How HMRC interpret the three conditions, the origins of their approach, and the evolution of their guidance and practice over the last decade
• How the Targeted Anti-Avoidance Rule (TAAR) operates and what this means in real-world scenarios
• How the Bluecrest case progressed through the First-tier Tribunal, Upper Tribunal, Court of Appeal and Supreme Court, and what the final judgment means for the application of the salaried members’ rules in practice
• How HMRC are likely to approach compliance activity and enquiries following the Supreme Court’s judgment
• Practical steps you can take now to ensure LLP members continue to be taxed as self-employed and how to reduce the risk of HMRC challenge

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.