The LLP Salaried Members Rules - Compliance, Challenges & Case Law

Introduction

The Supreme Court has announced it will hear part of the appeal in the Bluecrest salaried members’ case. Meanwhile, HMRC remain highly active - in BGC Services Holdings LLP, they have issued a £96m determination - without providing any reasons.

With the salaried members’ rules under the spotlight for the past 18 months, this new virtual classroom seminar provides both a refresher and a practical exploration of some of the more challenging aspects. Aimed at accountants, legal and tax advisors, this session will ensure you and your clients remain compliant amidst this evolving landscape.

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, the changes over the last decade, and the significant shifts in early 2024 followed by their U-turn a year later
• How the Targeted Anti-Avoidance Rule (TAAR) operates and what this means in real-world scenarios
• What to expect from the Supreme Court, how the case law has evolved through the First Tier Tribunal, Upper Tribunal, and Court of Appeal, and what this could mean for future compliance
• Practical steps you can take now to ensure LLP members are 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.