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FTT decides that IR35 does not apply to consideration attributable to exploitation of image rights (Bryan Robson Ltd v HMRC)

Published on: 28 January 2025

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  • Why it matters
  • Case details

Article summary

Tax analysis: In Bryan Robson Limited v HMRC the First-tier Tax Tribunal (FTT) allowed in part the taxpayer company’s appeal against PAYE determinations and NIC decisions under the intermediaries’ legislation (IR35). The FTT held that the legislation applied to the company’s 2019 contract with Manchester United except to the extent that it related to image rights. The decision is in principle only; the FTT left the parties to agree the figures

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