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Christianuyi: HMRC steps up MSC enforcement

The Court of Appeal has recently interpreted the MSC legislation more widely than expected, paving the way for HMRC to target arrangements previously thought to be low risk, as Kevin Barrow and Ian Hyde (Osborne Clarke) explain.

In this article we look at the recent Court of Appeal (CA) decision in Christianuyi v HMRC [2019] EWCA 474 (Civ) and how this is likely to impact the industry of accountancy advisers connected to the personal service company (PSC) world their PSC contractor clients and potentially the staffing agencies or hirers that referred the contractors to the accountancy advisers in the first place. In some ways this represents a bigger threat to the PSC industry than the proposed IR35 reforms.

What is the MSC legislation?

The managed service companies (MSC) legislation set out in ITEPA 2003 Chapter...

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