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Contentious tax: quarterly review

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3 June 2019
Card image Adam Craggs
Card image Constantine Christofi

Adam Craggs and Constantine Christofi (RPC) consider the recent spate of IR35 cases that have been considered by the First-tier Tribunal, HMRC's increasing use of 'jeopardy amendments' and the increasing number of judicial review challenges being brought against HMRC.  

IR35

There have been five cases on the application of the intermediaries legislation (contained in ITEPA 2003 s 49 and Social Security Contributions (Intermediaries) Regulations SI 2000/727 reg 6) so-called ‘IR35’ since the beginning of 2018: Christa Ackroyd Media v HMRC [2018] UKFTT 69 (TC); MDCM Ltd v HMRC [2018] UKFTT 201 (TC); Jensal Software Ltd v HMRC [2018] UKFTT 271 (TC); Albatel v HMRC [2019] UKFTT...

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