HM Revenue and Customs v HFFX LLP & ors

Tuesday 9 – Wednesday 10 July 2024

By an Appellant’s Notice filed on 24 May 2023, HMRC Appeals the decision dated 20 March 2023 of Mr Justice Mellor and Judge Swami Raghavan sitting in the Upper Tribunal (Tax and Chancery Chamber) dated 20 March 2023 which dismissed an appeal against a decision of the FTT.

By an Appellant’s Notice filed on 25 May 2023 the Appellants (Alexander Gerko and Others) appeal different parts of the same decision

The individual Taxpayers were involved with coding and developing programming for automated FX trading. They became members of the LLP Appellant HFFX LLP (“HFFX”). The individual Taxpayer, Alexander Gerko was the managing member of HFFX.

The dispute between the Taxpayers and the Respondent, HMRC, concerns the tax treatment of a deferred remuneration arrangement for individuals known as the Capital Allocation Plan (“CAP”).

View hearing:

Day 1

Part 1

Part 2

Day 2

Part 1