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- Heading
- Introduction
- The legislation and the issue before the FTT
- the approach to determining whether the intermediaries legislation applies
- the FTT’s decision
- hmrc’s grounds of appeal
- approach to hmrc’s grounds of appeal
- ground 1: the third rmc stage
- Discussion: business on own account in different contexts
- Atholl House
- The FTT’s approach to the Third RMC Stage
- Did the FTT err in law in its approach to the Third RMC Stage?
- Conclusions