UT (Tax & Chancery) UT-2022-000134 UT-2022-000135 UT-2022-000137 - [2025] UKUT 00214 (TCC)

Mr Lopez was a Director and Senior Rates Trader at MHI during the Relevant Period.

Mr Lopez was an experienced trader. He had worked at Credit Suisse and BNP Paribas in non-trading roles early in his career. He returned to Credit Suisse in July 2007, with a sales role in fixed income derivatives and structured products. In September 2012 he transferred to work as a junior EGB trader on the fixed income desk; this was his first job as a trader. He reported in that role to Mr Urra (who had joined Credit Suisse in August 2011) until September 2013, when Mr Urra moved to MHI. Mr Lopez obtained his own book in June/July 2013 and was promoted in January 2015 but left Credit Suisse in December 2015, as Credit Suisse informed him that they would be closing the desk.

Mr Lopez joined MHI in February 2016 as Director and Senior Rates Trader in the Fixed Income Sales and Trading Department on the EGB Desk. Mr Urra had become aware that Mr Lopez was looking for a new role and informed the relevant individuals at MHI – Mr Lopez was interviewed by a number of individuals at MHI before being offered the role. Mr Lopez had been in advanced discussions in relation to a potential role at a hedge fund - that role would have involved more money, but he accepted the role at MHI as it was within his expertise and he wanted to prioritise spending time with his family.

Mr Lopez was still in his six-month probationary period at MHI during the Relevant Period. Nevertheless, he had his own book and was afforded a lot of independence in his role. Mr Heiberg’s opinion of him was that he was a “highly responsible individual with a strong moral compass”.

Mr Lopez left MHI in February 2020.