What the UK Supreme Court’s BlueCrest decision means for LLPs, International Tax Review

Partner Nick Fagge and counsel Elizabeth Spencer authored an International Tax Review article examining the UK Supreme Court’s landmark decision in HMRC v BlueCrest and its implications for limited liability partnerships (LLPs) relying on the “significant influence” test under the salaried members regime.

The authors explain that the decision clarifies that a member’s significant influence must derive from legally enforceable rights and duties under the LLP’s governing framework, rather than from de facto influence based on factors such as strong performance, financial contribution or client relationships. They also discuss the practical implications for investment manager LLPs, including the importance of executive committee participation and meaningful involvement in strategic or high-level decision-making.

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