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Conclusions
Disposition
For the reasons set out above, we have decided that Mr Burley remained entitled to his share of the profits of the Partnerships for the purposes of section 8 ITTOIA throughout the periods we are concerned with, and accordingly that the Closure Notices are correct.
This appeal is dismissed.
Right to Apply for Permission to Appeal
This document contains full findings of fact and reasons for the decision. Any party dissatisfied with this decision has a right to apply for permission to appeal against it pursuant to Rule 39 of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009. The application must be received by this Tribunal not later than 56 days after this decision is sent to that party. The parties are referred to “Guidance to accompany a Decision from the First-tier Tribunal (Tax Chamber)” which accompanies and forms part of this decision notice.
Release date: 14th AUGUST 2025
- Heading
- Introduction
- The Facts
- Mr Burley’s evidence
- Mr McErlean’s evidence
- Mr Pink’s evidence
- The Minute of Agreement
- The LLP’s Accounts
- Mr Burley’s Submissions
- HMRC’s Submissions
- Discussion
- The Tax Question: Was Mr Burley receiving/entitled to income from the Partnerships?
- The partnership law question: Did the Minute achieve what it set out to do (assign Mr Burley’s rights to income from the Partnerships)?
- Conclusions