contract agreement picture 3002431 1280

Latest IR35 Tribunal: Bryan Robson Ltd v HMRC

Date: 23/01/2025

contract agreement picture 3002431 1280

Bryan Robson’s appeal against the HMRC ruling on his owed tax from being in business on his own account has been a qualified success at First Tier Tribunal level.

The c.130 page Tax Chamber findings issued by tribunal judge Tony Beare were largely in favour of the famous footballer and manager covering tax periods between tax years ending 5th April 2016, and y/e 5th April 2021. The judgement was issued on 20th January this year. This case has covered a 10 year period and may still have further to run if HMRC choose to appeal to the Upper tribunal (and the whole case could go even further of course).

The findings have been covered elsewhere (e.g. https://www.freelanceinformer.com/news/ir35-what-freelancers-can-learn-from-bryan-robsons-tax-appeal-case-against-hmrc/ ) with comment.

Mr. Robson did well in the earlier tax years because the agreement was directly with him rather than an intermediary (his limited company), and therefore outside the scope of ‘IR35’.

However, latterly, the more recent form of agreement was with his limited company and therefore the assessment of whether there was an implied employment relationship was required. Here Mr. Robson faired less well. His situation was complicated by the point raised that his fees included some element of recognition for his licensed image rights to Manchester United FC. The judge has required the parties to agree the quantum of the fees due to these rights and outstanding NICs need to be paid on the remainder.

The findings are laid out in painstaking detail relate to the previous case law that has set precedent in some detail and the judge has laid his ‘working out’ down, which is useful to help with interpretation.

For those interested in the detail, the findings are at  https://www.bailii.org/uk/cases/UKFTT/TC/2025/TC09408.html

For members, please note that as part of your annual membership, you are covered by tax investigation insurance should the need arise and there is a route to Qdos for assessing your proposed outside IR35 contract forms should you wish to avail yourselves.

IIM Interim Management Survey Report 2025 Cover

The IIM Interim Management Survey 2025

The Final Report has now been published and can now be accessed.

Want to fast track your interim career or expand your professional network?

Be part of the UK’s only community dedicated to Interim Professionals.

All comments

You must be a member to view and post comments

Related News

IIM Interim Management Survey Report 2025 Cover

Date: 19/06/2025

IIM Interim Management Survey 2025 Final Report

We are pleased to announce the publication of the 2025 IIM Interim Management Survey Report,...
MarksSattin

Date: 23/08/2023

IIM welcomes Marks Sattin as an Affiliate

The Institute of Interim Management (IIM) is delighted to welcome Marks Sattin as a new...
dreamstime m 207431596

Date: 22/05/2023

ISP & Consultant Winners Announced

We are delighted to confirm that New Street Consulting Group have been named No1 Service...
IR35 Contracts

Date: 31/03/2023

Eamonn Holmes IR35 tax appeal dismissed by Upper-Tribunal

The IR35 case involving television presenter Eamonn Holmes has taken another decisive turn, with the...
HW Interim

Date: 19/12/2025

IIM welcomes HW Interim Solutions as a new Affiliate

The Institute of Interim Management (IIM) is pleased to welcome HW Interim Solutions as a new...
SheffieldHaworth

Date: 20/11/2025

IIM announces Sheffield Haworth as an Affiliate

The Institute of Interim Management (IIM) is pleased to announce that Sheffield Haworth has become...
dreamstime xl 133359628

Date: 14/02/2024

The Steps to Building a Successful Interim Career

Interims are a vital part of today’s business landscape. The interim talent market is strong,...
woocommerce placeholder

Date: 19/09/2023

Companies House to Get New Charging Powers

The Economic Crime and Corporate Transparency (ECCT) Bill is making its way through Parliament and...
EdenBrownSynergy

Date: 01/11/2024

IIM welcomes Eden Brown Synergy as an Affiliate

The IIM (Institute of Interim Management) is pleased to announce that Eden Brown Synergy has...
Heads Group

Date: 15/04/2024

IIM welcomes Heads Resourcing as an Affiliate

The Institute of Interim Management (IIM) is pleased to welcome Heads Resourcing Group as an...
C LptIDe

Date: 23/09/2022

Kwarteng Quashes Latest IR35 Changes

Today, the Chancellor of the Exchequer, Kwazi Kwarteng, announced his ‘mini-budget’. This ought to be...
Closed

Date: 24/04/2025

Annual Survey 2025 is now CLOSED

The 2025 IIM Interim Management Survey is now CLOSED. A huge THANK YOU to everyone...
contract agreement picture 3002431 1280