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The First-tier Tribunal decision in Christianuyi Ltd concerning managed service companies.
KEY POINTS
- The MSC legislation in ITEPA 2003 s 61A to s 61J was introduced in 2007.
- The behaviour of the accountancy provider can be crucial.
- The provider in Christianuyi was found to be involved with the companies.
- Check periodically to ensure arrangements are understood and followed.
- Read HMRC’s guidance in the Employment Status Manual.
Congratulations to HMRC on a significant victory in the tax tribunal. This is a rather uncharacteristic reaction from me but it is the only appropriate one after HMRC’s win in Christianuyi Ltd and others (TC5045) in which the tribunal decided the taxpayers had been managed service companies.
As the result of seeing so many businesses operate models that appear to be sailing very close to the wind and so little action apparently being taken against them those...
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