BlueCrest’s Michael Platt loses UK tax tribunal appeal

A First-tier Tribunal ruled in favour of HM Revenue & Customs after examining arrangements that routed Michael Platt’s remuneration and investment income through entities based outside the UK. The tribunal concluded the income should have been subject to UK tax.

The case focused on historical arrangements that involved non-UK companies and trusts used in connection with payments to Platt. The ruling covers past tax years rather than current structures.

Michael Platt co-founded BlueCrest Capital Management in 2000 and led the firm to manage tens of billions of dollars at its peak. In 2015 BlueCrest returned external capital and converted into a private partnership that manages the wealth of its partners and employees; it no longer manages third-party capital.

The ruling was issued amid increased scrutiny by UK tax authorities of senior investment managers and the use of offshore entities. Authorities have examined carried interest arrangements, cross-border compensation structures and other international arrangements to determine tax treatment under updated rules and transparency standards.

The tribunal’s decision applies to the facts and tax years considered in the case.