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Mutuality of obligation
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Mutuality of obligation
MUTUALITY-OF-OBLIGATION
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
Georgia Hicks (Devereux Chambers) unpacks the Supreme Court decision,
considers the state of the employment status test, and gives guidance
for taxpayers.
The Court of Appeal’s guidance on IR35 employment status
Georgia Hicks
Georgia Hicks (Devereux Chambers) examines two cases which seek to give authoritative guidance on the application of the
Ready Mixed Concrete
and business on own account tests.
The Court of Appeal’s ruling in PGMOL: seven lessons on mutuality of obligation
Georgia Hicks
Jonathan Peacock QC
As the dispute between PGMOL and HMRC goes back to round one, counsel for the taxpayer, Georgia Hicks (Devereux Chambers) and
Jonathan Peacock QC (11 New Square), consider what the Court of Appeal judgment means for taxpayers in the employment status debate.
Professional Game Match Officials: HMRC wins appeal but court orders a replay
Rebecca Seeley Harris
What can be gleaned from the Court of Appeal's recent judgment?
IR35 changes imminent: what do they mean?
Rebecca Wallis
Stephen Pevsner
Stephen Pevsner and Rebecca Wallis (Proskauer Rose) address the practical
issues surrounding compliance with the off-payroll working rules for private
sector clients due to be introduced from 6 April.
HMRC v Kickabout Productions Ltd
Mutuality of obligation crucial in UT’s reversal of FTT’s IR35 decision.
IR35: why (and when) mutuality of obligation matters
Derek Francis
Contrary to HMRC’s guidance and CEST tool, mutuality of obligation is pivotal to determining employment status in surprising ways. Derek Francis (Terra Firma Chambers) examines cases showing how.
Professional Game Match Officials: clarity on mutuality of obligation
Mark Groom
A recent Upper Tribunal decision provides three guiding principles on mutuality of obligation, writes Mark Groom (Deloitte).
EDITOR'S PICK
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
1 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
2 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
3 /7
Estoppel and abuse of process in VAT
Claire Logan
4 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
5 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
6 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
7 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
Estoppel and abuse of process in VAT
Claire Logan
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
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UK closes the door on foreign branch loss relief
VAT capital goods scheme changes
New guidance on UK-India social security agreement
Mandatory registration brought into force, eventually
HMRC annual report: compliance yield tops £50bn
CASES
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St Patrick’s International College Ltd and others v HMRC
M Lambourne and another v HMRC
HMRC v Align Technology Switzerland GmbH and another
Other cases that caught our eye: 17 July 2026
HMRC v BlueCrest Capital Management (UK) LLP
IN BRIEF
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Directors’ liability: tax schemes
BlueCrest: the impact for asset managers
When Ramsay does not rescue HMRC
Tax Update 2026: Plans to reform the income tax payment regime: a significant acceleration of ITSA tax liabilities
Tax Update 2026: Modernising the distributions framework: familiar routes for extracting value or reorganising companies may change
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Consultation tracker
When Ramsay does not rescue HMRC
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Legislation Day 2026: The securities transfer tax