M Rangos v HMRC

In M Rangos v HMRC (TC01893 – 29 March) five companies which traded in tickets for various events went into liquidation. The Official Receiver formed the opinion that all five companies had been under the control of an individual (R) who had been a director of one of the companies and had acted as a ‘shadow director’ of the other companies. HMRC issued determinations under Income Tax (PAYE) Regulations SI 2003/2682 reg 80 and issued a notice of direction under reg 81(4) requiring R to pay the tax in question. R appealed denying that he had been a shadow director of two of the companies. The First-tier Tribunal reviewed the evidence in detail and upheld the direction in principle finding that R had been ‘a shadow director and thus an employee’ of the two companies in question. (However ...