Secret Hotels2: The behaviour of an agent versus principal

March 01 2013

With the Secret Hotels2 Limited decision released on December 3 2012, the UK Court of Appeal has provided guidance on the correct approach to be taken when determining who is the supplier of a service in agency / principal arrangements, explain Mark Delaney and Arianne Wijdeveld of Baker & McKenzie.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

more across site & shared bottom lb ros

More from across our site

Direct Tax

A taxing week: Trump’s pillar two deal won’t save the project

The EU has seemingly capitulated to the US’s ‘side-by-side’ demands. This may be a win for the US, but the uncertainty has only just begun for pillar two

Sam Sholli, December 22 2025

Direct Tax

MHA acquires tax and consulting services firm in UAE

The £7.4m buyout marks MHA’s latest acquisition since listing on the London Stock Exchange earlier this year

Sam Sholli, December 22 2025

Direct Tax

Editor’s picks: ITR’s top stories of 2025

ITR’s most prolific stories of the year charted public pillar two spats, the continued fallout from the PwC Australia tax leaks scandal, and a headline tax fraud trial

Tom Baker, December 22 2025

Direct Tax

This week in tax: EU nations drop US pillar two carve-out objections

The climbdowns pave the way for a side-by-side deal to be concluded this week, as per the US Treasury secretary’s expectation; in other news, Taft added a 10-partner tax team

Sam Sholli, December 19 2025

Direct Tax

Hogan Lovells, Cadwalader to merge in ‘largest combination in history’

A vote to be held in 2026 could create Hogan Lovells Cadwalader, a $3.6bn giant with 3,100 lawyers across the Americas, EMEA and Asia Pacific

Noemi Distefano, December 18 2025

Direct Tax

Whose tax is it anyway – Libya’s permanent establishment conundrum

Foreign companies operating in Libya face source-based taxation even without a local presence. Multinationals must understand compliance obligations, withholding risks, and treaty relief to avoid costly surprises

Salaheddin El Busefi , December 18 2025

Indirect Tax

HMRC scores Supreme Court VAT victory over Hotel La Tour

Hotel La Tour had argued that VAT should be recoverable as a result of proceeds being used for a taxable business activity

Sam Sholli, December 17 2025

Direct Tax

EY recruits provided AI training but still taught ‘old way’

Tax professionals are still going to be needed, but AI will make it easier than starting from zero, EY’s global tax disputes leader Luis Coronado tells ITR

Sam Sholli, December 17 2025

Direct Tax

KPMG reports 7.5% tax and legal services revenue increase

AI and assisting clients with navigating global tax reform contributed to the uptick in turnover, the firm said

Sam Sholli, December 16 2025

Direct Tax

US Treasury secretary eyes pillar two deal finalisation this week

In a post on X, Scott Bessent urged dissenting countries to the US/OECD side-by-side arrangement to ‘join the consensus’ to get a deal over the line

Tom Baker, December 16 2025