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

UT (Tax & Chancery) Case Number: UT/2019/0000122

Hearing venue: Rolls Building

Fetter Lane

London

EC4A 1NL

Judgment date: 07 April 2025

INCOME TAX AND NATIONAL INSURANCE CONTRIBUTIONS – IR35 – intermediaries legislation – FTT not entitled to make certain findings as to the terms of the hypothetical contract – material error of law – decision of FTT set aside and remade

BETWEEN

-and-

Representation:

For the Appellant: Michael Paulin, instructed by way of direct access

For the Respondents: Sadiya Choudhury KC, instructed by the General Counsel and Solicitor to HM Revenue and Customs

DECISION