Matt Parfitt and Edmund Paul explore the key considerations around managed service companies and the case of Christianuyi
With the imminent introduction of the IR35 changes, contractors and their clients may be looking at how engagement structures could be changed going forwards. One area of tax legislation that could impact alternative arrangements is the managed service companies (MSC) legislation.
This legislation is particularly pertinent, having been tested for the first time in the recent tax case of Christianuyi Ltd and others v HMRC, which has made its way through the First-tier Tribunal, the Upper Tribunal and the Court of Appeal.
All legislative references are to the Income Tax (Earnings and Pensions) Act (ITEPA) 2003.