In Serpol Ltd v HMRC (TC01043 – 11 April) a company (S) supplied the services of various staff (mostly former police officers) to the Bedfordshire Police.
HMRC issued determinations charging tax under Income Tax (PAYE) Regulations 2003 SI 2003/2682 reg 80. S appealed contending that the workers were performing ‘excluded services’ within ITEPA 2003 s 47(2)(b)(ii) so that it was not required to account for PAYE.
The First-tier Tribunal allowed the appeal in respect of ‘project managers’ and staff who took witness statements or worked from home on various projects but dismissed the appeal in respect of disclosure officers indexers exhibit officers and ‘scene of crime’ officers who ‘were required to carry out their duties as required by the nature of the services’.
Why it matters: ITEPA 2003 ss 44–47 deals with the...
