R (oao UK Uncut Legal Action Ltd) v HMRC

The case of R (oao UK Uncut Legal Action Ltd) v HMRC (QB – 16 May) follows on from the widely publicised case of Goldman Sachs International v HMRC (No. 2) (2010 SFTD 930) in which HMRC had issued a ruling to a company (GSI) that the exercise of certain options to employees gave rise to a liability to national insurance contributions. GSI appealed contending that the staff were supplied by an associated company (GSL) and applied for a preliminary hearing to determine whether it could be treated as the employer of the employees who had exercised the options. The First-Tier Tribunal held a preliminary hearing reviewed the evidence in detail and determined the preliminary issue in favour of HMRC finding that GSL ‘did not have a place of business in Great Britain at any time relevant...