The right of substitution – recent developments
‘Personal service’ is an important factor in determining whether various pieces of tax legislation apply, including IR35 and sections 44-47 ITEPA. Two recent cases appear to highlight a possible conflict in approach. 1) HMRC v Talentcore (2011). This case concerns the Agency Worker Tax Rules (sections 44-77 ITEPA). Individuals were supplied to cosmetic companies for […]
