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The evidence and the key submissions
The evidence and the key submissions
The documents for the hearing (set out at para. 8 above) comprised pleadings, documents relating to HMRC’s investigation, and appeal correspondence. The Hearing Bundle also contained the statements of the Appellant’s witnesses.
We heard evidence on behalf of the Appellant from Mr Stone, Mr Thornborrow and Mr O’Ryan. We considered the evidence given by all of the witnesses to be of assistance to us in understanding the background, as set out in the “Background Facts”. A number of admissions were made by the Appellant’s witnesses, which we will set out in our “Discussion” later.
- 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