The concepts used in para. 28(2) – (4) are concepts drawn from employment contracts. In respect of the equivalent earlier proposed version of the SRT the ICAEW said:

‘We are also concerned that such a test is very focussed on the position of employers and employees. It does not cater satisfactorily for someone who may be self-employed where work patterns can be very different.’

753

The December 2012 ConDoc recorded that:

‘Concerns were … raised about whether the test was appropriate for the self employed and entrepreneurs, as well as part-time and rotational workers.’

754

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