TC09663 - [2025] UKFTT 01250 (TC)

The Appellant’s clients include Wembley National Stadium (“the FA”), the All-England Lawn Tennis Club (“Wimbledon”), Tottenham Hotspur Football & Athletic Co. (“Spurs”), Chelsea Football Club (“Chelsea”), Fulham Football Club (“Fulham”), London Stadium 185 (Queen Elizabeth Olympic Park), Laing O’Rourke (“Tideway”), and several other minor clients. By way of example, the ‘service’ provided by the Appellant is set out in the following terms (“the Fulham contract”):

“BETWEEN:

FULHAM FOOTBALL CLUBLimited, a company registered in England … (the "Fulham"); and

TYLER SECURITYLimited, a company registered in England under number 6412278 and VAT Registered whose registered office is at 23 Copthorne Avenue... (the "Service Provider");

…

Invoices, with the fee calculated on the number of “dog teams” (i.e., a combination of dog and handler), are provided by the Appellant to the end-client. An example of one such invoice is to “BMB JV” is as follows:

“Supply of one Narcotics Search Dog & Handler at £240

BMB JV West Site

…

Task Order No. 3 of 10 13 February 2020”

Given the trading patterns of its clients, the Appellant neither maintains a workforce, nor owns or maintains its detection dogs or transport. The Appellant became an Approved Contractor Scheme (“ACS”) with the Security Industry Authority (“SIA” (Footnote: ⁴)) in March 2014. The Appellant subcontracts its dog detection services to specialist businesses.