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MWL International Ltd and Maywal Ltd v HMRC [2024] UKFTT 402 (TC) The companies dealt in tangible commodities, sourcing from multiple overseas jurisdictions and supplying markets across the Middle East. From 1989 onwards, the company owned or leased vehicles that were luxury limousines fitted with telephone capability (using Bluetooth during the years under appeal). The cars were provided to clients visiting the UK and, at other times, were placed at the disposal of, and used by, one or more directors and employees, notably W, his spouse LW, and his son MW. Save for a single vehicle, the fleet was kept at the home of W and LW, which also functioned as the company’s registered office. In 2021 HMRC issued determinations imposing Class 1A NICs in relation to the vehicles, and the company brought an appeal. It maintained that the vehicles met the statutory requirements to qualify as pool cars, or, alternatively, that a 1993 agreement meant either HMRC was estopped from asserting they were not pool cars, or the...