The government agency is demanding £29.8m in pay-as-you-earn tax and has lodged a county court claim for £5.5m in national insurance contributions, according to statements in Cheyne’s accounts for the year to December 31. The disputes relate to the tax years 2004-05 and 2006-07.
The $6.8bn hedge fund has criticised the action and said HMRC has “presented no technical argument supporting their position”.
“The company has appealed against these potential liabilities. The directors and the company’s professional advisors believe that HMRC’s claims are without merit and that recent case law supports this view.”
Cheyne, set up by Jonathan Lourie and Stuart Fiertz in 1999, believes HMRC is targeting a series of firms in financial services and beyond and that many more will receive demands. A spokesman added: “Cheyne and our advisors are comfortable with our position.”
HMRC said it does not comment on specific cases and that there is no clampdown on hedge funds but added that it was responsible for making sure the “right tax is paid at the right time”.