THE COMMISSIONERS FOR HIS MAJESTY鈥橲 REVENUE AND CUSTOMS v RALC CONSULTING LIMITED [2024] UKUT 00099 (TCC)
Upper tribunal Tax and Chancery decision of Mr Justice Richards and Judge Ashley Greenbank on 12 April 2024
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INCOME TAX 鈥� NATIONAL INSURANCE CONTRIBUTIONS 鈥� intermediaries legislation 鈥� sections 48 to 61 Income Tax (Earnings and Pensions) Act 2003 鈥� Social Security Contributions (Intermediaries) Regulations 2000 鈥� whether First-tier Tribunal erred in failing properly to construct hypothetical contract 鈥� yes 鈥� whether First-tier Tribunal erred in its application of the test of mutuality of obligation to the hypothetical contract 鈥� yes 鈥� appeal allowed 鈥� decision set aside and case remitted to First-tier Tribunal
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Published 15 April 2024