A recent IR35 tribunal judgment draws a line between services and image rights, and shows the consequences of HMRC errors, writes David Harmer (Markel Tax).
The Bryan Robson Ltd v HMRC [2025] UKFTT 56 (TC) judgment is a recent IR35 case focusing on ‘personalities’ operating through their own limited company. In recent years we have seen a spate of similar cases where HMRC have challenged the IR35 status of presenters commentators and similar occupations (see cases such as Atholl House [2024] UKFTT 37 (TC) and S&L Barnes [2024] UKUT 262 (TCC)). However this isn’t simply just ‘another IR35’ case. There are a number of elements to this case which saw the need for detailed discussion and examination the most pertinent of which being the written contracts image rights and HMRC errors.
The facts of the case
Robson ex MUFC and England football captain provided...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
A recent IR35 tribunal judgment draws a line between services and image rights, and shows the consequences of HMRC errors, writes David Harmer (Markel Tax).
The Bryan Robson Ltd v HMRC [2025] UKFTT 56 (TC) judgment is a recent IR35 case focusing on ‘personalities’ operating through their own limited company. In recent years we have seen a spate of similar cases where HMRC have challenged the IR35 status of presenters commentators and similar occupations (see cases such as Atholl House [2024] UKFTT 37 (TC) and S&L Barnes [2024] UKUT 262 (TCC)). However this isn’t simply just ‘another IR35’ case. There are a number of elements to this case which saw the need for detailed discussion and examination the most pertinent of which being the written contracts image rights and HMRC errors.
The facts of the case
Robson ex MUFC and England football captain provided...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
