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Cards on the table

10 June 2014 / Mike Truman
Issue: 4455 / Categories: Comment & Analysis , Employees , Income Tax

Why Reed Employment failed in its application for judicial review of HMRC’s decision to revoke PAYE dispensations


  • Upper Tribunal upholds original First-tier Tribunal decision.
  • One small appeal relating to the facts was accepted.
  • Judicial review requires cards to be “face upwards on the table”.
  • Ample evidence for First-tier tribunal to conclude that Reed had not done so.

The Upper Tribunal has heard the case of Reed Employment plc & others [2014] All ER (D) 153 and has upheld the decision of the First-tier Tribunal for HMRC. I wrote about the latter two years ago in my article No sacrifice at all.

Sharp dealing

To briefly summarise the facts Reed had received a dispensation in respect of travel and subsistence payments made to staff who were supplied as temps as part of Reed’s business and who allegedly attended temporary places of employment.

The staff...

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