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England and Wales decisions
Decisions matching the current search
The Tribunal held that PGMOL’s match engagements with National Group referees were contracts for services, not employment, so the PAYE and NIC appeals succeeded.
Commissioners for His Majesty's Revenue and Customs v MR Currell Ltd [2026] EWCA Civ 445 (17 April 2026)
The Court of Appeal dismissed HMRC’s appeal, holding that a genuine, repayable loan funded through an employee benefit trust was not taxable earnings under section 62 ITEPA.
The Court of Appeal dismissed HMRC’s appeal over whether an EBT-funded loan to a director counted as earnings. The genuine repayable loan was not taxable remuneration.
The First-tier Tribunal dismissed Ms Clark’s costs application, holding it lacked jurisdiction to award costs for pre-appeal conduct and that HMRC’s post-appeal conduct was not unreasonable.
The First-tier Tribunal refused BGC’s request for a preliminary hearing on Regulation 80(1), finding the issue risked overlap with best judgement and could trigger costly appeals.
The delay in appealing was serious and significant, no good reason was provided for the delay, and balancing all circumstances, the prejudice to the appellant did not outweigh the lack of justification for the delay. Permission to appeal out of time was refused.
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The Tribunal refused permission for a late appeal due to the serious and significant delay, lack of merit in most reasons for delay, and the overriding importance of statutory time limits and efficient litigation outweighing prejudice to Mr Benson.
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The Court of Appeal dismissed Mainpay’s tax appeal, holding that each assignment was a separate employment and that HMRC’s carelessness case was made out.
Mainpay Ltd v Commissioners for HM Revenue and Customs [2025] EWCA Civ 1290 (10 October 2025)
The Court of Appeal dismissed Mainpay’s appeal, holding that each assignment was a separate employment and that HMRC’s out-of-time assessments were valid.
The Upper Tribunal held that the First-tier Tribunal misapplied employment-status rules in a Carer’s Allowance overpayment appeal and remitted the case for reconsideration.
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