Weekly case highlights ― 12 August 2024

Produced by a Tolley Owner-Managed Businesses expert

Owner-Managed Businesses

Guidance

These are our brief notes and thoughts on cases published in the last week or so which caught our eye and are likely to be of particular interest to tax practitioners. Full case reports and commentary on most of these cases will be included within our normal reference sources in the coming weeks.

Employment tax

Cranham Sports LLP v HMRC

Although it relates to an IR35 dispute the real interest in this case is procedural. The tennis commentator Barry Cowan provided his services to Sky TV via a limited liability partnership in which he was a member.

HMRC believed that IR35 applied to the contractual arrangements and raised PAYE and NIC determinations accordingly. These were appealed and correspondence with HMRC continued.

Eventually HMRC issued a ‘view of the matter’ letter to the taxpayer’s agent confirming that it continued to hold the view that IR35 applied. It outlined the three options that the taxpayer could pursue.

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