EXCHEQUER SOLUTIONS LTD v THE COMMISSIONERS FOR HIS MAJESTY鈥橲 REVENUE AND CUSTOMS [2024] UKUT 00025 (TCC)
Upper Tribunal Tax and Chancery decision of JUDGE SWAMI RAGHAVAN and THE CHANCELLOR on 24 January 2024
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PAYE & NIC 鈥� travel and subsistence expenses paid by umbrella company servicing construction industry clients鈥� whether mutuality of obligation to constitute overarching contract of employment or whether arrangement amounted to series of individual assignments in which case travel expenses not allowable as ordinary commuting expenses 鈥� FTT correct to find no overarching contract of employment 鈥� FTT also correct to reject appellant鈥檚 argument that Regulation 80 Income Tax (Pay as You Earn) Regulations 2003 invalid and that reimbursement of expenses were not subject to NICs 鈥� appeal dismissed
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Published 25 January 2024