UK: England and Wales: the definition of ‘managed service company provider’

This post, UK: England and Wales: the definition of 'managed service company provider',  by noreply@blogger.com (Robert Goddard), first appeared on  at http://corporatelawandgovernance.blogspot.com/.

The Court of Appeal gave judgment earlier this week in Christianuyi Ltd & Ors v Revenue And Customs [2019] EWCA Civ 474. The decision is an important one – now the leading authority – on the definition of managed service companies (MSCs) and MSC providers within the tax anti-avoidance framework, following decisions of the Upper and First-tier Tribunals (see, respectively: [2018] UKUT 10 (TCC) and [2016] UKFTT 272 (TC)).

Specifically, the court considered the definition of MSC provider within section 61B of the Income Tax (Earnings and Pensions) Act 2003 and rejected the argument that, in order for a company to be a MSC provider, it was necessary for that company – in addition to being in the business of promoting or facilitating the use of companies through which individuals provide their services to clients – also to promote or facilitate the services provided by those companies.

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