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PD & MJ Ltd v HMRC

UT dismisses IR35 appeal by Sky Sports pundit.

In PD & MJ Ltd v HMRC [2025] UKUT 94 (TCC) (17 March) the UT dismissed the company’s appeal holding that the IR35 intermediaries legislation applied to arrangements under which the company supplied the services of former footballer Phil Thompson to Sky TV as a pundit.

Mr Thompson appeared for many years on the Sky TV show Soccer Saturday. Between 2013 and 2017 his services to Sky were provided through the appellant company. HMRC considered that the intermediaries legislation in ITEPA 2003 ss 48-61 applied to the arrangements and assessed the company to PAYE and NIC accordingly. The company appealed.

The FTT had dismissed the company’s appeal applying the three-stage approach in HMRC v Atholl House Productions Ltd [2022] EWCA Civ 501. The company appealed to the UT on the grounds that the FTT had made errors of law...

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