Billionaire Michael Platt’s hedge fund, BlueCrest Capital Management, has criticised the UK’s business environment after losing a Supreme Court tax dispute with HM Revenue & Customs (HMRC).
The loss leaves the firm facing a bill of almost £200million.
The Supreme Court unanimously ruled in HMRC’s favour, concluding BlueCrest is liable for around £143million in income tax and more than £55million in National Insurance contributions.
The case centred on whether payments made to members of the firm’s limited liability partnership should be treated as partnership distributions or taxed as employment income.
The court found most payments amounted to “disguised salary” because the remuneration was not determined solely by the partnership’s profits or losses.
As a result, they should be taxed as employment income rather than partnership profit shares.
BlueCrest, which has been in dispute with HMRC since 2022, said the ruling undermined confidence in the UK tax system and its attractiveness as a place to do business.
A spokesman said: “Businesses operating in the UK need to be able to rely on HMRC’s guidance to organise their tax affairs with certainty… Without that certainty, and in an increasingly competitive global market, the UK is no longer a serious contender as a jurisdiction in which to do business.”
Michael Platt is the CEO at BlueCrest Capital Management
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MICHAEL PLATT/LINKEDIN
The firm argued throughout the case it had structured its arrangements in line with HMRC’s published guidance, saying after the judgment that the guidance “was, and remains, wrong.”
The decision has prompted concern across the hedge fund industry.
Rob Hailey of the Managed Funds Association said the UK’s competitiveness as a global investment‑management hub depends on certainty and predictability.
He warned the ruling could have broader implications at a time when policymakers are trying to attract investment and strengthen the UK’s position as a financial centre.
BlueCrest loses £200million HMRC Supreme Court tax case as hedge fund criticises UK business climate
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GETTY“Firms need a stable and predictable environment to make long‑term investment decisions,” he said.
It is the second major Supreme Court tax defeat for a London hedge fund in recent months.
Last month, billionaire trader Alex Gerko lost a separate challenge over the tax treatment of profits generated by a currency‑trading fund.
Mr Platt, born in Preston, is one of Britain’s best‑known hedge fund managers, with an estimated fortune of around £11.2billion.
He founded BlueCrest in 2000 with fellow trader William Reeves, and the firm has reported strong performance in recent years, including returns of 93 per cent last year, driven partly by positions against the US dollar.
The ruling could have implications beyond BlueCrest’s own tax affairs.
HMRC launched investigations into London hedge funds CQS and Cheyne Capital Management in 2021, and the judgment is expected to be closely watched by other firms facing similar issues.
It also comes amid wider concerns about the UK’s competitiveness as a destination for financial‑services businesses, with industry groups calling for greater certainty over tax and regulation.