Personal service companies, which each provided the professional services of their owners and sole directors to third parties, were managed service companies (within the meaning of the managed service company legislation).
The owners and sole directors of the appellant companies each provided their professional services to third parties via a personal service company. HM Revenue and Customs issued income tax determinations (under SI 2003/2682, reg 80) and notices of decision for National Insurance contributions purposes (under SSC(TF)A 1999, s 8) for the tax years 2007/08 to 2009/10 inclusive. The appellants appealed.
The First-tier Tribunal (FTT) ([2016] UKFTT 272 (TC)) considered whether the appellant companies were managed service companies (MSCs) within the meaning of the MSC legislation (in ITEPA 2003, Pt 2, Ch 9). It was conceded that another company (CBS) to which arrangements concerning the appellants related was&
