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The issue
The issue
The sole issue to be determined is whether the Agency legislation applies to the engagement of the dog-handlers during the relevant period. (Footnote: 3) This, in turn, requires consideration of whether the dog-handlers personally provided services to another person, under a contract, and subject to the supervision, direction and control (“SDC”) by any person.
In this Decision, the legislation and case law are cited so far as is relevant to the issue in dispute.
- 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