Bryan Robson Ltd v HMRC

In Bryan Robson Ltd v HMRC [2025] UKFTT 56 (TC) (20 January) the First-tier Tribunal (FTT) allowed in part the taxpayer company’s appeal against PAYE determinations and NIC decisions under the intermediaries legislation (IR35) ruling 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.  

The company was the personal service company of former Manchester United and England footballer Bryan Robson. He acted in an ambassador role for the club for many years under a series of agreements. It was agreed before the tribunal that only the 2019 agreement between the club and the company was in dispute the previous agreements having been made between the club and Mr Robson personally. Under the 2019 agreement...