MAINPAY LIMITED v THE COMMISSIONERS FOR HIS MAJESTY’S 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 – umbrella company engaging temporary workers – reimbursement to workers of subsistence expenses by reference to scale rates – whether reimbursement payments deductible – whether each workplace attended by worker was a permanent workplace – whether contract was an overarching contract of employment or, if not, a single employment – whether payments using scale rates were deductible without an HMRC dispensation – establishing whether loss of tax brought about carelessly so that extended time limit for making an assessment applied