INCOME TAX – PAY AS YOU EARN – NATIONAL INSURANCE CONTRIBUTIONS – Intermediaries Legislation – IR35 – Personal Service Companies (PSC) – s.49 of the Income Tax (Pay As you Earn) Act 2003 (ITEPA) – Determinations under Regulation 80 of the ITEPA Regulations 2003 – Provision of IT consultancy services – notional or hypothetical contracts to be constructed —four links in chain between Mr Alcock, the Appellant PSC (RALC), the agencies (Networkers and Capita) and end clients (DWP or Accenture) – notional contracts of service (employment) or contracts for services (self-employed) – Ready Mixed Concrete Test – four year time limit under s. 34 of the Taxes Management Act 1970 (TMA) – carelessness of Appellant or its adviser under s. 118 of the TMA – extended time limits of six years under s. 36(1) or (1B) TMA – appeal allowed
Citations:
[2019] UKFTT 703 (TC)
Links:
Jurisdiction:
England and Wales
Income Tax
Updated: 06 December 2022; Ref: scu.646873