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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
Jonathan Peacock QC
Georgia Hicks
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
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
1 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
2 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
3 /7
Loopholes and tax avoidance
Kyle Rainsford
4 /7
Spare us the cUTTer
Nick Thornton
5 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
6 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
7 /7
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
Loopholes and tax avoidance
Kyle Rainsford
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
NEWS
Read all
Tax Update 2026: government publishes simplification and compliance package
HMRC asked to clarify CIS treatment of development finance
HMRC Transfer Pricing and Profit Diversion Compliance Facility
ICTS consultation
UK-India Double Contributions Convention arrangements extended
CASES
Read all
HMRC v HFFX LLP; Atkins and others v HMRC
The Trustees of the Panico Panayi Accumulation and Maintenance Settlements Nos. 1 to 4 v HMRC and Redevco Properties UK 1 Ltd v HMRC
Other cases that caught our eye: 26 June 2026
HMRC v Bolt Services UK Ltd
Barclays Bank plc v HMRC
IN BRIEF
Read all
Foreign PE exemption becoming mandatory
Solving the LLC double taxation problem
AI in R&D advisory: seven control points
Information notices
Management rollovers and share-for-share exchange relief
MOST READ
Read all
Solving the LLC double taxation problem
Consultation tracker
Foreign PE exemption becoming mandatory
HMRC v GCH Corporation Ltd and others
HMRC consult on taxation of UK-resident members of LLCs and other ‘reverse hybrids’