UK IR35 Status Determination Statement (SDS) Dispute Letter (ITEPA 2003 s.61T)
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Your Engagement
Tell us about the engagement, the SDS you have received, and the date you received it (this starts the 45-day clock).
This letter will cite
ITEPA 2003 Chapter 10 Part 2 (ss.61M-61X) + s.61T(3) 45-day disagreement window + s.61N(3)-(4) deemed fee-payer + HMRC v Atholl House Productions Ltd [2022] EWCA Civ 501 + Kickabout Productions Ltd v HMRC [2022] EWCA Civ 502
Your letter will trigger the client-led disagreement procedure in s.61T, citing the 45-day deadline, and apply the Court of Appeal multi-factor test to your engagement.
Off-payroll working is UK-wide tax legislation. The substantive rule is the same in all three nations — only the local FTT hearing centre and signposting differ.
This is the start of the 45-day window under ITEPA 2003 s.61T(3). The deadline is calculated from this date.