TC09613 - [2025] UKFTT 00989 (TC)

We turn now to address the two questions which confront us, the partnership law question whether Mr Burley’s assignment of his rights to receive income from the Partnerships had been validly effected, and the tax law question whether, assuming the assignment had been validly effected, Mr Burley remained the person who received or was entitled to the income of the Partnerships. Because, perhaps unusually for tax questions, we can answer this question in a clearer and more definitive way, we will deal first with the tax question.