HMRC won at UT on appeal. Interesting legal analysis. Shows yet gain what an incomprehensible mess IR35 is.
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What is really interesting about this case is that it is another in a respectable number of cases where the member has dissented and the dissent was upheld by the UT or above.
I have sat with Charles Baker and he is very good and very knowledgable, so much so that in another case the Judge left him to write the decision.
Other such cases include the McLaren case where Nicholas Dee's dissent was upheld, and of course Rangers where the Supreme Court praised Heidi Poon's dissent.