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G Lineker and another t/a Gary Lineker Media v HMRC

IR35, partnerships and direct contracts

In G Lineker and another t/a Gary Lineker Media v HMRC [2023] UKFTT 340 (TC) (27 March 2023) the First-tier Tribunal (FTT) held that while the IR35 rules apply to general partnerships the contracts under which Mr Lineker provided his services were direct contracts between him and broadcasters. As a result the IR35 rules were not applicable.

In 2013 the BBC entered into an agreement with Gary Lineker former footballer and sports broadcaster and his then wife Danielle Bux (formerly Danielle Lineker) for the provision of Mr Lineker’s services; the contract was signed by Mr and Mrs Lineker as ‘the partners’ of Gary Lineker Media (GLM) referred to as ‘the partnership’. In 2015 BT Sport entered into an agreement with Mr and Mrs Lineker ‘trading as [GLM] (“Partnership”)’ for the provision of Mr Lineker’s services; the...

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