Canal Street Productions Ltd v HMRC

In Canal Street Productions Ltd v HMRC [2019] UKFTT 647 (TC) (25 October 2019) the First-tier Tribunal allowed the appeal of a television presenter’s personal service company (PSC) against HMRC’s determination that IR35 applied to the PSC’s arrangement with ITV.

Helen Fospero a TV presenter incorporated her PSC Canal Street Productions Ltd in 2002 when taking a role with the BBC. She continued to contract through her PSC with different broadcasters (including ITV) through to 2012 and then entered into contractual arrangements in respect of appearances on programmes ‘Daybreak’ and ‘Lorraine’. This arrangement came to an end in 2014.

HMRC asserted that IR35 (found at ITEPA 2003 ss 48-62) applied to the arrangements in 2012 to 2014. The dispute was on whether the condition in ITEPA 2003 s 49(1)(c) was met namely if Ms Fospero’s services had been provided under a contract directly between...

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