TC09663 - [2025] UKFTT 01250 (TC)

Case Number: TC09663

[Taylor House]

Appeal reference: TC/2022/12739

INCOME TAX – Determination under regulation 80 of the Income Tax (Pay As You Earn) Regulations 2003 – specialist dog handlers engaged by Appellant for its end-clients – the application of the Agency Rules – sections 44 – 47 of the Income Tax (Earnings and Pensions) Act 2003 –whether the Agency legislation applies to the Appellant – whether the dog handlers personally provided services to the end-clients – whether there was supervision, direction and control by ‘any person’ – whether there was a failure to make the required payments as required by regulation 67G of the PAYE Regulations – yes – Appeal dismissed

Judgment date: 16 October 2025

Before

JUDGE NATSAI MANYARARA

DR CAROLINE SMALL

Between

TYLER SECURITY LIMITED

Appellant

and

THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS

Respondents

Representation:

For the Appellant: Mr Andrew Young of Counsel, instructed by Lexlaw Solicitors & Advocates

For the Respondents: Mr Christopher Stone KC and Mr Josh Neaman of Counsel, instructed by the General Counsel and Solicitor to HM Revenue and Customs

DECISION