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HMRC v Basic Broadcasting Ltd

In HMRC v Basic Broadcasting Ltd [2024] UKUT 165 (TCC) (7 June) the UT decided that there had been an error of law by the FTT when considering the taxpayer’s hypothetical contract with the client in the light of the CA’s decision in Atholl House [2022] EWCA Civ 502.

Between 6 April 2012 and 5 April 2017 the television and radio presenter Adrian Chiles supplied his services to ITV and the BBC through his personal service company Basic Broadcasting Limited.

HMRC considered that the intermediaries legislation (IR35) applied and raised determinations on the company for income tax of £1 249 433 and NICs of £460 739 (ITEPA 2003 ss 48-61 SI 2000/727 for NIC).

The saga has been subject to considerable delays. The original FTT hearing scheduled for November 2019 was abandoned due to illness. The FTT decision in February 2022 in the taxpayer’s favour...

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