DRAGONFLY
CONSULTANCY LTD v REVENUE & CUSTOMS COMMISSIONERS (2008)
[2008]
EWHC 2113 (Ch)
Ch D (Henderson J) 3/9/2008
TAX
- CONTRACTS - EMPLOYMENT - INFORMATION TECHNOLOGY
CONTRACTS
OF EMPLOYMENT : CONTROL : INFORMATION TECHNOLOGY : INTENTION : MUTUALITY OF
OBLIGATION : NATIONAL INSURANCE CONTRIBUTIONS : PAYE : SUBSTITUTION : WORKERS :
PROVISION OF SERVICES THROUGH INTERMEDIARY : SERVICE COMPANIES : IR 35 :
CONTRACTS OF SERVICE : HYPOTHETICAL CONTRACT : Sch.12 FINANCE ACT 2000 : reg.6
SOCIAL SECURITY CONTRIBUTIONS (INTERMEDIARIES) REGULATIONS 2000
The taxpayer company, which supplied the services of
its sole director as an IT systems tester to a client through an intermediary,
was liable to account for income tax and national insurance contributions under
the IR 35 legislation contained in the Finance Act 2000 Sch.12 and the Social
Security Contributions (Intermediaries) Regulations 2000 reg.6 since a contract
directly between the director and the client would have been a contract of
employment.
The
appellant company (D) appealed against the dismissal of its appeals against
determinations of liability to PAYE income tax for three tax years and a decision
in respect of liability to national insurance contributions in respect of the
same period
D's
sole director (B) was an IT systems tester
B held
50 per cent of the shares in D
D was a
service company which supplied B's services to an end-user (C) via an agency
The
agency had agreed to supply C with such temporary staff as it might require in
the fields of data processing, computing and project management
Pursuant
to the agreement, the agency had indicated to C that it intended to supply B's
services as a consultant
The
relationship between D and the agency was governed by a series of fixed-term
contracts
There
was no written contract between D and B
B had
worked almost exclusively for C on testing three projects for periods of 7, 22
and 9 months respectively
The
Special Commissioner agreed with the respondent commissioners' view that D was
liable to pay national insurance contributions and PAYE income tax under the IR
35 legislation contained in the Finance Act 2000 Sch.12 for income tax and the
Social Security Contributions (Intermediaries)
Regulations 2000 reg.6 for national insurance on the basis that, if
B's services had been provided under a contract directly between B and C, B
would have been regarded as an employee of C for tax purposes
D
contended that the Special Commissioner had erred in law in (1) concluding that
the right of substitution within the notional contracts would not have been
inconsistent with employment; (2) concluding that the notional contracts would
have contained provisions conferring on C a sufficient right of control to
justify the conclusion that the contracts would have been contracts of service;
(3) concluding that the intentions of the parties were irrelevant; (4)
directing himself that the relevant dividing line lay between being in business
on one's own account and employment, without taking into account the fact that
an individual might be a "worker" rather than an employee.
HELD:
(1) Whether a relationship was an employment one or not required an evaluation
of all of the circumstances
The
context was one where the answer to be given depended on the relative weight to
be given to a number of potentially conflicting indicia
The
presence of a substitution clause pointed towards self-employment, but was not
necessarily determinative, Usetech Ltd v Young (Inspector of Taxes) (2004) EWHC 2248 (Ch),
(2004) STC 1671 applied
The
Special Commissioner had been entitled to conclude that the notional contracts
between C and B would have been for the services of B, and would have provided
that he could send a substitute only if C had given notice that that particular
substitute was acceptable in place of B for such period as it should specify
A
limited right of substitution in those terms would have been compatible with
the existence of a relationship of employment between C and B, Express & Echo Publications Ltd v Tanton
(1999) ICR 693 CA (Civ Div) distinguished
(2) On
the evidence, the Special Commissioner was fully entitled to conclude that B's
performance of his duties was subject to a degree of supervision and quality
control that went beyond merely directing him when and where to work
In the
case of a skilled worker, control over how the work was done would not be
expected
Conversely,
in the case of a self-employed worker in business on his own account regular
appraisal and monitoring of the kind attested to in the instant case would not
be expected
The
weight and significance to be attached to the evidence was a matter for the
Special Commissioner, and it was open to him to conclude that the nature and
degree of the control by C under the hypothetical contract was on balance a
pointer towards employment
(3)
Statements by the parties disavowing any intention to create a relationship of
employment could not prevail over the true legal effect of the agreement
between them
In the
instant case, the inclusion of a term in the hypothetical contract to the
effect that the parties did not intend to create a relationship of employment
could not by itself have reasonably permitted the Special Commissioner to reach
the opposite conclusion about B's notional status as an employee
(4) In
the context of IR 35, the only distinction that mattered was whether the
notional contract would be a contract of service or not
The
Special Commissioner clearly had that distinction well in mind, and his
conclusion that B fell on the employment side of the line was unassailable.
Appeal dismissed
Counsel:
For the appellant: Andrew Stafford QC
For the respondents: Susan Chan
Solicitors:
For
the appellant: Nelsons Solicitors LLP
For the
respondents: In-house solicitor
LTL 4/9/2008 (Unreported elsewhere)
Judgment:
Official - 24 pages
Document No. AC0118387
Source: Lawtel http://www.lawtel.co.uk
, copyright acknowledged.