The Taxpayer-Appellant, a successful and independent media and sport commentary company, has been granted to permission to appeal following an oral permission hearing before Judge Ramshaw in McCann Media Ltd v The Commissioners for His Majesty’s Revenue and Customs UT-2022-000023. Michael Paulin represented the Appellant, instructed by Tax Networks Ltd.

The Upper Tribunal held that it was arguable that the First Tier (Tax) Tribunal had erred with respect to the issue of mutuality of obligations, had failed to take into account and/or properly apply the third limb of Ready Mixed Concrete (South East) Ltd v Minister of Pensions and National Insurance [1968] 2 QB 497, namely other factors of the contractual relationship were inconsistent with employment, and finally; that the First-tier Tribunal had arguably erred in applying the three-stage test in Revenue & Customs Commissioners v Kickabout Productions Ltd [2020] UKUT 216 (TCC).

Michael is currently instructed by several taxpayers, including large businesses, concerning the application of the provisions in Chapter 8 of Part 2 Income Tax (Earnings and Pensions) Act 2003 (“ITEPA 2003”) – often referred to as the ‘IR35’ rules.

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