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This was a procedural application by the taxpayer to amend its grounds of appeal.
GLM was a partnership established in 2012 between Gary Lineker and his former wife Danielle Bux. During the tax years 2013-14 to 2016-17 Mr Lineker contracted to provide his services to the BBC through GLM. He also provided his services to BT Sport through the partnership during 2015-16 to 2017-18.
HMRC considered that the arrangements fell within the intermediaries legislation - IR35 - and issued determinations under reg 80 of the Income Tax (PAYE) Regulations 2003.
The partnership wished to add two new grounds of appeal. These were that the taxpayer’s liability was overstated and the 2013-14 notice was invalid because HMRC did not have ‘sufficient facts’ to issue an opinion on the National Insurance liability. HMRC opposed the application because both grounds were ‘insufficiently precise for either HMRC or the tribunal to understand what...
