Hedge fund Bluecrest Capital Management, founded by the UK’s wealthiest financier, has lost a court appeal over a £200m tax feud with HMRC, in a ruling that could now leave the wider professional services industry facing a hefty tax bill. The UK’s Supreme Court ruled against the hedge fund run by
Rosie Harris-Davison
Wednesday 01 July 2026 10:38 am
Hedge fund Bluecrest Capital Management, founded by the UK’s wealthiest financier, has lost a court appeal over a £200m tax feud with HMRC, in a ruling that could now leave the wider professional services industry facing a hefty tax bill.
The UK’s Supreme Court ruled against the hedge fund run by billionaire Michael Platt, unanimously rejecting its argument its senior traders were technically self employed and therefore not subject to employers’ National Insurance.
The court ruled that traders in a Limited Liability Partnership (LLPs) must be taxed as employees rather than as self-employed profit-sharers. Bluecrest now faces a near £200m tax bill as a result of the ruling.
The legal battle centres on so-called salaried member rules which determine whether LLPs, which include the majority of law and professional services firms, including the Big Four, are self-employed or ‘disguised employees’, for tax reasons. The case could now wider ramifications for the professional services industry and open the door to a major tax bill from HMRC.
HMRC initiated the dispute after auditing Bluecrest for the tax years 2014/15 to 2018/19 and determining that almost all Bluecrest members, except a few executive committee members, were ‘salaried members’. As a result, it sought to collect income tax and national insurance contributions.
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Platt was was named the 12th wealthiest person in the UK by the Sunday Times Rich List last year, and Britain’s wealthiest hedge fund manager with an estimated net worth of nearly £13bn.
BlueCrest Capital Management reported a significant revenue surge to £130.8m for the year ending 31 March 2025, a 149 per cent increase from £52.6m the previous year.
Back and forth in court
The case first went to a First-Tier Tribunal in March 2021, which found that bonuses based on individual members’ performance constituted “disguised salary.”
However, the tribunal also ruled partially in favour of Bluecrest, finding that its portfolio managers had “significant influence” over the firm because of the financial impact of their roles, even if they were not in senior management roles.
Both parties then appealed to the Upper Tribunal, which held a hearing in June 2023, and the tribunal largely upheld the FTT’s decision, however in January In January, the highest court heard BlueCrest’s appeal, and rejected their arguments that the members had substantial financial influence.
Bluecrest has been contacted for comment.
Read more LLPs remain under watchful eye – especially from the taxman
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