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P Ormandi v HMRC

CIS deductions and double taxation

In P Ormandi v HMRC [2019] UKFTT 667 (5 November 2019) the FTT upheld determinations issued by HMRC in respect of amounts which a contractor had failed to deduct under the CIS scheme even though the result was double taxation. 

Mr Ormandi carried on business as a painter and decorator. He also undertook work installing flooring fitting kitchens and bathrooms and constructing outdoor decking using sub-contractors. However he had failed to make deductions from the payments made to the sub-contractors under the CIS scheme. He appealed against determinations made by HMRC under the Income Tax (Construction Industry Scheme) Regulations 2005 in relation to amounts which HMRC claimed should have been deducted from payments made by him to his sub-contractors. 

Mr Ormandi accepted that deductions should have been made but he challenged the amounts on the ground that the relevant sub-contractors...

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