Personal service companies, each of which provided the professional services of their owners/sole directors to third-parties, were managed service companies as the company which had set them up was a ‘managed service company provider’ within the relevant 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 (ITEPA 2003, Pt 2, Ch 9). It was originally conceded