Dramatis personae
Dramatis personae
Mr Rowland Stone was appointed Director of the Appellant on 30 October 2007. Mr Stone previously worked as a police officer for 32 years. Shareholding is split between Mr Stone and his wife, on a 60:40 basis.
Mr Frank Thornborrow offers specialist dog detection services, together with a trained search dog. His clients primarily include security companies. He worked as dog-handler in the City of London Police for 16 years, and retired in 2014. Since then, he has been working as a dog-handler in the private sector.
Mr Cefyn O’Ryan is the director of Baseline Security Services Ltd (“Baseline”), which offers specialised security search services to security companies. Baseline was incorporated on 29 December 2022, which is after the relevant period. There is no evidence to the effect that Mr O’Ryan was otherwise engaged by the Appellant during the relevant period.
Mr Goode is a dog-handler who worked for the Appellant.
- Heading
- Introduction
- The issue
- Burden and standard of proof
- Authorities and documents
- Background facts
- Dramatis personae
- The end-clients
- The dog-handlers
- HMRC’s investigation
- The Determination
- Relevant law
- ITEPA
- The PAYE Regulations
- TMA
- The evidence and the key submissions
- The Appellant’s submissions
- HMRC’s submissions
- Findings of fact
- Discussion
- Whether the Agency legislation applies
- Condition 1: s 44(1)(a)
- An individual (‘the worker’)
- ‘ Personally provided services ’
- Supervision, Direction and Control
- Conclusions
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