The only thing that seems to be reasonably clearly confirmed is what we all knew all along, which is that HMRC's argument that any work related contract of any kind is enough for MOO is patently nonsense (or at least that bit of the UT's decision does not seem to have been criticised by CoA in para 95).
https://www.bailii.org/ew/cases/EWCA/Civ/2021/1370.html
That said, whatever MOO is or isn't, it seems MOO's absence is not determinative and you must consider all other factors regardless per para 119.
It's been remitted to FTT to decide. Good luck to anyone who can make sense of this and apply it accurately to any particular facts. What a mess and how on earth is the CEST tool supposed to figure this out if these judges can't?
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I trust that any trip back to the FTT is via the SC.
But, why is it going back to the FTT? It's not to hear new evidence - the FTT are to make a decision on "the basis of its original findings of fact". The reason given is that the FTT is a specialist court is suspect as the FTT is a specialist in tax law and the matter to be decided is an issue of contract law. Also the CoA spent its time picking holes in the UT and FTT's analyses, yet the CoA claims to know less about the relevant law than the FTT.