EXCHEQUER SOLUTIONS LTD v THE COMMISSIONERS FOR HIS MAJESTY’S 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 – travel and subsistence expenses paid by umbrella company servicing construction industry clients– 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 – FTT correct to find no overarching contract of employment – FTT also correct to reject appellant’s argument that Regulation 80 Income Tax (Pay as You Earn) Regulations 2003 invalid and that reimbursement of expenses were not subject to NICs – appeal dismissed