Hoey v HMRC [2022] EWCA Civ 656 (Court of Appeal)

Citation:

[2022] EWCA Civ 656 (Court of Appeal)

Judgment Date:

13 May 2022

Barrister:

Taxation contractor loan arrangements – PAYE liability – judicial review HMRC discretion to transfer PAYE liability from end user to contractor

– Appeal from UT – jurisdiction of the FTT to consider PAYE credits – application of TOAA code to the arrangements – payments wholly and exclusively for the purposes of a trade.