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Tyra Ali

After finishing her law degree Tyra spent a number of years working for HMRC dealing with S.9a enquiries, CIS compliance, PAYE, travelling and subsistence and other compliance areas.  After several years of swiftly working through the grades she joined Markel Tax in 2006.  She brought with her a wealth of knowledge in many areas including specialist IR35 off-payroll and self-employment; CIS, Agency Legislation, National Minimum Wage and defending clients against all types HMRC challenges. Tyra has successfully defended many clients in relation to IR35, Employment Status, MSC, Umbrella and CIS , HMRC penalties and assisting in many high-profile IR35 tribunal cases

App Accounting Group contractors getting their 10 days against HMRC is an important milestone. Yet answers at the FTT hearing to the core MSC questions seem as far off as resolution day.

Two cases brought by HMRC are now distinctly different, yet ‘judgement day’ for Churchill Knight and Boox contractors alike may not even fall this side of the decade.

HMRC’s ‘retrospective due diligence’ -- revisiting MSC determinations mid-appeal to request the actual income data -- is unprecedented. So too will be the FTT’s decision in just six months.

A single test involving a Boox contractor, and the separate test case for CK contractors, could be scheduled before 2025 is out.

Seemingly because a protected agency is also a protected client, a ruse is on to convince contractors they have an insurable interest -- when they don’t.

19th January, 2023 | Private Sector IR35 Reform