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Who pulls the strings?
KEY POINTS
- The managed service company legislation is in ITEPA 2003 s 61A et seq.
- Christianuyi is the first significant case on the managed service company legislation.
- The provider was confirmed as being involved with the companies.
- Result may affect people working through personal service companies that are managed by a third party.
The Upper Tribunal’s decision in Christianuyi Ltd and others v CRC is an important reminder for tax professionals of HMRC’s powers over managed service companies.
In particular it should be examined by workers who provide their services through a personal service company (contractors) the agencies and recruiters that promote the use of such arrangements and accountants and tax advisers who are involved in advising in this area.
The result of this case is likely to concern people who decided or were encouraged to...
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