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Ground 1
Ground 1
We turn first to HMRC’s first ground of appeal: that the FTT failed properly to identify the terms of the hypothetical contracts and to apply the common law test of employment status to those terms as required by section 49(1) ITEPA.
- Heading
- Introduction
- Background
- The relevant legislation
- The FTT Decision
- The Grounds of Appeal
- Ground 1
- Background
- The parties’ submissions
- Discussion
- Case law guidance on the correct approach
- The FTT’s approach in this case
- Conclusions
- Ground 2
- Background
- The parties’ submissions
- Discussion
- Relevant case law
- The FTT’s approach to mutuality of obligation
- Conclusions