Richard Alcock, an IT consultant, was the sole director and shareholder of RALC Consulting Limited, and for five years worked through his personal services company for management consultancy Accenture and the Department for Work and Pensions (DWP) on fixed term contracts.

HMRC had lost an earlier First Tier Tribunal (FTT) hearing in October 2019 over whether RALC Consulting Limited owed tax and penalties for tax years 2010/11 to 2014/15 under the application of the intermediaries legislation to the contractual arrangements.

The amounts of income tax and NICs (excluding interest) at issue are £164,482 and £78,842 respectively, totalling £243,324.

The FTT ruled in favour of Alcock, stating that he had not broken the rules over the construction of the hypothetical contract and test of mutuality of obligation under IR35 rules.