Christianuyi and others v HMRC

In Christianuyi and others v HMRC [2019] EWCA Civ 474 (19 March 2019) the Court of Appeal found that a company which set up companies for the provision of services by individuals but was not involved in promoting the services of those individuals was a managed service company (MSC) provider so that the companies were MSCs.

All the appellants were companies which provided the services of an individual who was their sole shareholder and director. They contracted with end clients and charged fees for the services which were then paid out to the individual. 

The issue was whether the appellants were MSCs and whether Costelloe which had set them up was a managed service company provider within the meaning of ITEPA 2003 s 61B. Costelloe did not promote or facilitate the services of each individual and each appellant negotiated its own...