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Digital Subscriptions > The Hedge Fund Journal > Issue 115 - July | August 2016 > The Taxman Cometh – Are You Prepared?

The Taxman Cometh – Are You Prepared?

Key tax considerations affecting investment managers in the UK

HMRC is increasingly focussing on the tax affairs of investment management businesses, particularly those structured as LLPs. We discuss below two particular areas of HMRC interest, and the strategies that businesses should be considering in order to best position themselves to deal with such interest.

The present (and future)

HMRC introduced the ‘salaried member’ rules in April 2014. These rules required LLPs to look at each of their individual members, and determine whether each member should be treated as self-employed or as an employee for UK tax purposes (with the corresponding differences in the application of the tax and national insurance regimes), by applying three separate tests. The tests involve considering whether:

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