Bryan Robson Limited v HMRC: A 1-1 Draw

The First-tier Tax Tribunal recently released a decision on the application of the IR35 legislation to payments made by Manchester United Football Club (MUFC) to Bryan Robson Limited, the personal service company (the PSC) of Bryan Robson (the former long-serving MUFC football player and England captain).

The IR35, or "off-payroll working", rules apply where a worker who provides services to a client through their own intermediary (often a PSC) would have been considered an employee if they had been providing their services directly to that client. If the rules apply, the worker (in this case, Mr Robson) will be deemed as an employee of the client (in this case, MUFC) and will be subject to PAYE and NICs on his earnings.