An application by a partnership to amend its grounds of appeal in an IR35 case was allowed by the First-tier Tribunal.
The appellants traded as a partnership (GLM), which was established in 2012. During the tax years, 2013/14 to 2016/17 inclusive, one of the partners (GL) contracted to provide his services to the BBC through GLM. He also provided his services to BT Sport through GLM during the tax years 2015/16 to 2017/18 inclusive.
HM Revenue and Customs (HMRC) considered that such arrangements fell within the ambit of the intermediaries (‘IR35’) legislation and issued determinations under the Income Tax (Pay As You Earn) Regulations 2003, SI 2003/2682, reg 80 in respect of income tax deductible via PAYE, and notices under SSC(TF)A 1999, s 8 in respect of Class 1 National Insurance contributions.
GLM