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Ground 2
Ground 2
HMRC’s second ground of appeal is that FTT erred in law in its approach to mutuality of obligation; and erred in law and/or reached a perverse conclusion in finding that, within the actual LLCs and ULCs, there was not sufficient mutuality of obligation.
- 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