THE COMMISSIONERS FOR HIS MAJESTY’S 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 – NATIONAL INSURANCE CONTRIBUTIONS – intermediaries legislation – sections 48 to 61 Income Tax (Earnings and Pensions) Act 2003 – Social Security Contributions (Intermediaries) Regulations 2000 – whether First-tier Tribunal erred in failing properly to construct hypothetical contract – yes – whether First-tier Tribunal erred in its application of the test of mutuality of obligation to the hypothetical contract – yes – appeal allowed – decision set aside and case remitted to First-tier Tribunal