Tyler Security appealed to the First Tier Tribunal (FTT) after HMRC issued a determination related to PAYE and the agency legislation. 

The appellant, Tyler Security, was set up in 2007 and provides specialist search dogs, primarily used for detecting explosives, firearms, pyrotechnics and narcotics, with teams of search-dog operatives and their dogs integral to client contracts for some of the country’s top sporting venues.

Client companies pay fees for the services to Tayler Security and these are calculated based on the number of search-dog operatives - handlers - and dogs provided, and the number of hours worked. The appellant’s business model incorporates these dog-handlers as integral components of the security services it delivers to its clients, the tribunal said.