In our March UK Tax Round Up, we reported that the First-tier Tribunal (FTT) ruled in favour of Hargreaves Lansdown that "loyalty bonuses" (or "trail commissions") paid to investor clients which represented sums rebated by investment fund managers from their management fee were not "annual payments" and so not subject to withholding tax. HMRC has now appealed this decision. As mentioned in our March edition, this decision is of general interest to UK fund general partners and investment managers who might operate management fee rebate arrangements with certain of the fund's investors.