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E an analyst programmer was the sole director and owner of 50% of the shares in the appellant company. Between 1998 and 2002 an agency P arranged for his services to be provided to company L.
There was no contact between L and E or E and the appellant which agreed to provide services to L.
E worked for 37.5 hours a week within a team at L's premises on a succession of projects. He completed timesheets and the appellant invoiced P.
E was not paid sick leave or holiday pay and did not have any other staff benefits.
In April 2002 it was agreed that the appellant had the right to provide a substitution worker in addition to or in the place of E.
HMRC considered that between 2000 and 2002 the Social Security Contributions (Intermediaries) Regulations SI 2000 No 727 ...
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