An introduction to new team members at A&M Taxand – Lewis Whitehill, Associate and Graeme Connell, Senior Director

A&M is pleased to welcome a number of new team members to the Taxand practice in Glasgow including new Associate Lewis Whitehill and new Senior Director Graeme Connell. 

Mr. Whitehill has over 7 years of experience in Funds tax compliance, with a specific focus on listed open-ended investment companies, Unit Trusts and Investment Trusts which are administered by large Asset Houses.  His expertise covers both UK corporate tax and non-UK investor tax reporting compliance. 

With over 13 years of experience in a wide range of areas of U.K. and international taxation, Mr. Connell has worked with clients ranging from large U.K. and international corporations to ultra-high net worth individuals. His expertise includes advising on a wide range of corporate and individual tax issues, with a particular focus on corporate group and debt reorganizations, corporate transactions, and other complex matters.

Salaried member rules’ recent case, BlueCrest Capital Management (UK) LLP v HMRC

The recent decision of the First-tier Tribunal (FTT) in BlueCrest Capital Management (UK) LLP v HMRC (29 June 2022) is the first case that considered the salaried member rules in the context of an asset management LLP.

We have provided further details of the case here and how A&M can help. This is a significant case as so far, there has been no judicial consideration of the salaried member rules and businesses have had to rely on HMRC’s guidance only.

In summary, the FTT found that certain of BlueCrest’s members with responsibility for managing key investment portfolios, had ‘significant influence’ over the affairs of the LLP, even though their influence was financial rather than managerial. This decision is welcomed by asset management LLPs. It is yet to be seen whether HMRC will appeal the decision.

The UK Mini-Budget 2022

On Friday 23 September 2022, the former UK Chancellor of the Exchequer, Kwasi Kwarteng, unveiled the biggest package of tax cuts in 50 years. We had prepared a detailed summary of the Mini-Budget here. 

Following the change in Chancellor in recent days, a number of the previously announced tax changes from the Mini-Budget have now been reversed.  A summary of the Chancellor’s statement on Monday 17 October is here.

We should have more information on the personal tax implications for Scottish resident taxpayers shortly.