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Findings of fact
Findings of fact
The “Background Facts” are not in issue between the parties, save that the parties differ in view as to the conclusions that we should reach as a result. We, therefore, adopt the Background Facts, at [9] to [33] above, as our “Findings of Fact”, and do not repeat these here. We derived considerable benefit from hearing the oral evidence in this appeal, and from considering the documents. Having heard the evidence, in summary, we find that the Agency legislation applies to the engagement of the dog-handlers in this appeal.
We give our reasons for so finding.
- 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