UT (Tax & Chancery) UT/2019/0000122 - [2025] UKUT 00124 (TCC)

For the reasons given above, we are satisfied that the errors of law identified by the appellant in Ground 1 and Ground 2 were material errors of law and that we must set aside the decision of the FTT. We have re-made the decision and for the reasons given above we are satisfied that the RBH hypothetical contract was a contract of employment. We therefore dismiss the appellant’s appeal against HMRC’s determination for income tax purposes and against HMRC’s decision for national insurance purposes.