In PD and MJ Ltd (in members' voluntary liquidation) v HMRC [2024] UKFTT 38 (TC) (11 December 2023) the FTT held that IR35 rules (ITEPA 2003 Part 2 Chapter 8 ss 48–61) applied to the services of football pundit Phil Thompson as supplied to Sky TV via his personal service company (PSC). Restrictions placed on Mr Thompson’s other work enabled the FTT to distinguish it from Stuart Barnes (S&L Barnes Ltd v HMRC [2023] UKFTT 42 (TC)).
HMRC assessed the PSC to £294 306.68 in income tax and NICs for four years 2013/14 to 2017/18 on the basis that the intermediaries legislation applied to Mr Thompson’s work on Soccer Saturday.
The employment status decision was made by the worker’s own PSC (ITEPA 2003 Part 2 Chapter 8) rather than by the hirer as would now be the case (under ITEPA 2003 ss 61K–61X except for...
