Churchill Knight & Boox clients being investigated as Managed Service Companies

[howbigmassive]

For those following the recent developments, my company Carbon Six has been involved in a protracted appeal against HMRC.

The Tribunal’s judgment has now been released. In it, HMRC’s conduct throughout the appeal was described by the Judge as ‘shambolic and haphazard’. Paragraphs 100 and 122 are particularly illuminating regarding the Revenue’s approach to these proceedings.

HMRC failed to meet the deadlines and directives issued by the Tribunal. Despite a formal warning that they would be barred if they did not comply, they subsequently failed to meet a second ‘Unless Order’.

HMRC applied to set aside the barring at a hearing on 14 January 2026. However, the Tribunal found that their application and skeleton argument contained incorrect and/or misleading statements (paragraph 122). Their excuses for the procedural failures were deemed ‘bad’ reasons, and the bar was upheld. As HMRC had failed to issue a Statement of Case, the Judge summarily allowed my appeal.

While the merits of the underlying tax case were not fully assessed due to the barring, the judgment highlights where HMRC’s conduct fell short of their duty to the court. Specifically:

• HMRC attempted to rely on superseded law (citing the Upper Tribunal decision in BPP), despite that logic being overturned or superseded by the Court of Appeal and Supreme Court.
• HMRC’s arguments—that a barring would lead to an ‘inequality of arms’ or a ‘windfall’ for the taxpayer—were specifically rejected as they ignored the binding precedents set by the higher courts.

I hope this provides some clarity for other contractors dealing with similar procedural issues. The case serves as a reminder that the Revenue is as bound by the Tribunal’s directives as any taxpayer.

[enda1]

Any date for an FTT hearing yet?

Sadly, I can see this dragging on for many years, possibly well into the 2030s. It's a complex case and, even if HMRC lost at the FTT (unlikely I know), they're bound to appeal to the UTT->CofA->SC.

Anyone caught up in this has my sympathy. You are being treated very unfairly and as though you used a dodgy tax avoidance scheme.

11th - 27th November, with reading days the 9th and 10th. At least this is for CK anyway. No idea for Boox.

[Domglym]

Churchill Knight / MSC Dispute – Anyone used the "Hays On-Site" defence for Debt Transfer?


Hi all, I’m one of the thousands caught in the Churchill Knight / HMRC Managed Service Company (MSC) investigation for the 2017/18 and 2018/19 tax years.

I’ve recently dug up some old onboarding documents from 2014 that show a very clear link between Hays Talent Solutions and Churchill Knight. Specifically, my "New Client Checklist" from CK has a mandatory step: "Agency informed of account activation?"

I’ve also identified the specific Hays consultant who was embedded on-site at UBS at the time. Their LinkedIn even confirms they were "on-site via Hays Talent Solutions" during my onboarding period in 2014.

My argument to HMRC is that this wasn't my choice of accountant—it was a mandated corporate workflow facilitated by the recruiter. Under Section 61D, I’m pushing for Debt Transfer to Hays as the "Involved" third party.

Has anyone else successfully used an "On-Site Agency" defense?
With the test cases supposedly pushed back to 2030, I’m wondering if naming the on-site rep makes HMRC more likely to "stay" the case or look at the agency instead.

Any advice or similar experiences would be massively appreciated!

[eek]

Churchill Knight / MSC Dispute – Anyone used the "Hays On-Site" defence for Debt Transfer?


Hi all, I’m one of the thousands caught in the Churchill Knight / HMRC Managed Service Company (MSC) investigation for the 2017/18 and 2018/19 tax years.

I’ve recently dug up some old onboarding documents from 2014 that show a very clear link between Hays Talent Solutions and Churchill Knight. Specifically, my "New Client Checklist" from CK has a mandatory step: "Agency informed of account activation?"

I’ve also identified the specific Hays consultant who was embedded on-site at UBS at the time. Their LinkedIn even confirms they were "on-site via Hays Talent Solutions" during my onboarding period in 2014.

My argument to HMRC is that this wasn't my choice of accountant—it was a mandated corporate workflow facilitated by the recruiter. Under Section 61D, I’m pushing for Debt Transfer to Hays as the "Involved" third party.

Has anyone else successfully used an "On-Site Agency" defense?
With the test cases supposedly pushed back to 2030, I’m wondering if naming the on-site rep makes HMRC more likely to "stay" the case or look at the agency instead.

Any advice or similar experiences would be massively appreciated!

the conclusion of that argument is that you were 100% inside IR35 but you are talking about a time when you were responsible for the assessment and payment of tax.

i wouldn’t personally use that argument

[howbigmassive]

I actually understand from my Tribunal in January this year (which did not consider the merits of the case, but upheld a barring order against HMRC in [2026] UKFTT 177 (TC)) that one group of test cases (I don't recall if it is CKA or TAAG) is likely to start in June 2026. There could be delays to that, but I'd expect at least an FTT hearing and judgment well before 2030, with expected appeals to UT and then higher, which means that the expected timeline for definitive judgment could be close to 2030.

[Fuzzynavel]

I've just got a letter this morning stating that the Boox MSCP lead cases are hitting the tribunal on the 15th June 2026 and that the hearing is expected to last 10 days.

This is ridiculous that it has gone on so long...It is also quite unfair that those of us who represented our cases and put in appeals are now targeted whilst those that ignored HMRC's bullying have been let off.

[rdw1970]

I've just got a letter this morning stating that the Boox MSCP lead cases are hitting the tribunal on the 15th June 2026 and that the hearing is expected to last 10 days.

This is ridiculous that it has gone on so long...It is also quite unfair that those of us who represented our cases and put in appeals are now targeted whilst those that ignored HMRC's bullying have been let off.

AFAIA there is just the one test case as the tribunal concerns a debt transfer notice from one Ltd Co to Boox (or The APP Accounting Group) to the Directors(s) of TAAG.

You're right, it is ridiculous but not surprising that its taken 4 years to get this stage and approx 250 Boox clients may have got off the hook by not responding to HMRC.