In HFFX LLP and Ors v HMRC [2023] UKUT73 the Upper Tax Tribunal held that profit shares distributed to individual LLP members after first being distributed to the corporate member were liable to income tax under the mixed membership rules - see further casenote at https://www.rossmartin.co.uk/sme-tax-news/6879-ut-partnership-planning-subject-to-income-tax.