MAINPAY LIMITED v THE COMMISSIONERS FOR HIS MAJESTY鈥橲 REVENUE AND CUSTOMS [2024] UKUT 00233 (TCC)

Upper Tribunal Tax & Chancery decision of MR JUSTICE ADAM JOHNSON and JUDGE THOMAS SCOTT on 16 August 2024

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INCOME TAX 鈥� umbrella company engaging temporary workers 鈥� reimbursement to workers of subsistence expenses by reference to scale rates 鈥� whether reimbursement payments deductible 鈥� whether each workplace attended by worker was a permanent workplace 鈥� whether contract was an overarching contract of employment or, if not, a single employment 鈥� whether payments using scale rates were deductible without an HMRC dispensation 鈥� establishing whether loss of tax brought about carelessly so that extended time limit for making an assessment applied

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Published 20 August 2024