Fees for services provided by an individual through his personal service company were not subject to the intermediaries (‘IR35’) provisions under a hypothetical employment contract between the individual and the end client.
Summary
Fees for services provided by an individual through his personal service company were not subject to the intermediaries (‘IR35’) provisions under a hypothetical employment contract between the individual and the end client.
Background
The appellant company provided construction management services to construction companies. The appellant’s directors and employees were D (i.e. the principal employee, who set up the company in 2004) and his wife.
HM Revenue and Customs (HMRC) believed that the intermediaries legislation (‘IR35’) applied to treat the appellant’s
