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Upper Tribunal agrees MSC provider was ‘involved’ with companies (Christianuyi Limited and others v HMRC)

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Published on: 22 January 2018
Published by a LexisNexis Tax expert
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Article summary

Tax analysis: Following the first judicial consideration of the managed service company (MSC) legislation by the First-tier Tax Tribunal (FTT) in 2016, the Upper Tribunal (UT) dismissed the appeal against the FTT’s finding that an MSC provider was ‘involved’ with the five appellant companies. This was the first time the UT had considered the MSC legislation, contained in sections 61A–61J of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003).

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Jurisdiction(s):
United Kingdom

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