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Analysis of the Gary Lineker and Eamonn Holmes appeals

17 April 2023 / Alastair Kendrick
Issue: 4884 / Categories: Comment & Analysis , HMRC , IR35 , Business , Investigations
No end in sight

Key points

  • The Lineker case was confined to looking at one aspect of IR35.
  • The tribunal decided that since the contracts had been signed by Mr Lineker personally in his capacity of principal no intermediary was involved.
  • Mr Lineker appears to have succeeded only because he rather than his partner signed the contracts.
  • In considering the nature of the contract between Red White and Green Limited and ITV the Upper Tribunal looked at the extent of control in detail.
  • An individual can be employed for some engagements and self-employed in relation to others.

In recent weeks the judgments have been released relating to the tax appeals of Gary Lineker and Eamonn Holmes in respect of claims by HMRC that they both should be taxed under IR35 (the intermediary rules) in regard to their respective media incomes.

The former (Gary Lineker and Danielle Box trading as Gary Lineker...

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