Catchwords:

TAXES AND DUTIES – payroll tax liability – employment agency contract – contract for trolley collection and cleaning services – identifying the employment agency contract – contract between agent and client – separate contracts between agent and service providers – onus of proof on tax payer

STATUTORY INTERRETATION – payroll tax liability – employment agency contract – procuring services for client – when service provider works “in and for” the business of the client of the agent – use of “indicia” – reliance on factors considered in other cases