In George Mantides Ltd v HMRC [2025] UKUT 124 (TCC) (6 March) the UT decided that locum urology services procured by the taxpayer company from its sole shareholder and director (M) would have given rise to a contract of employment with the recipient hospital had M provided the services directly. Accordingly the IR35 rules deemed the company to have paid M earnings subject to income tax and NICs.
M provided the services in question to Royal Berkshire Hospital (RBH) in 2013. In 2019 the FTT decided that the services gave rise to deemed earnings under the IR35 rules. The FTT also decided that M’s services to another hospital were outside the IR35 rules. That decision was not appealed because the FTT and the UT refused to give HMRC extra time to apply for permission to appeal (HMRC having failed to...
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In George Mantides Ltd v HMRC [2025] UKUT 124 (TCC) (6 March) the UT decided that locum urology services procured by the taxpayer company from its sole shareholder and director (M) would have given rise to a contract of employment with the recipient hospital had M provided the services directly. Accordingly the IR35 rules deemed the company to have paid M earnings subject to income tax and NICs.
M provided the services in question to Royal Berkshire Hospital (RBH) in 2013. In 2019 the FTT decided that the services gave rise to deemed earnings under the IR35 rules. The FTT also decided that M’s services to another hospital were outside the IR35 rules. That decision was not appealed because the FTT and the UT refused to give HMRC extra time to apply for permission to appeal (HMRC having failed to...
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