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Christianuyi and others v HMRC

In Christianuyi and others v HMRC [2018] UKUT 10 (19 January 2018) the UT found that the appellants were all managed service companies (MSCs) for the purpose of ITEPA 2003 s 61B(1).

The FTT had found that the appellants were MSCs with the effect that they were liable to income tax and NICs in respect to payments received by the individuals whose services were provided by the MSCs.

The main substantive issue was whether the condition of s 61B(1)(d) was satisfied: ‘a person who carries on a business of promoting or facilitating the use of companies to provide the services of individuals (‘an MSC provider’) is involved with the company’. The UT rejected the appellants’ contention that s 61 B(1)(d) is ambiguous. In particular the provision does not require a putative MSC provider to promote or facilitate the provision of an individual’s services. What is necessary is...

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