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IR35: HMRC losses match with Gary Lineker | accountingweb
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IR35: HMRC loses match with Gary Lineker

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Former professional footballer turned sports broadcaster Gary Lineker has won his long-running dispute with HMRC over £4.9m tax and national insurance, with the tribunal finding there was a direct contract between him and his clients.

29th Mar 2023
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Gary Lineker is probably the best-known football presenter in the UK, having hosted Match of the Day since 1999, and commentated on many European Championship and World Cup games. He highlighted his status as a freelancer when he recently was temporarily suspended from the BBC for making what some people viewed as an impartial political remark on Twitter. 

HMRC challenge 

HMRC asserted that Lineker’s work for the BBC between June 2013 and July 2016, and for BT Sport for the tax years 2013/14 to 2016/17, was caught by IR35 for tax and national insurance contribution (NIC) purposes (ITEPA 2003 chapter 8). This dispute was heard at the first tier tribunal (FTT) in January 2023 and the judgment was released on 28 March 2023 (TC 08774). 

An unusual aspect of this case is that the contracts to provide the personal services of Lineker to the BBC and to BT Sport were with a partnership: Gary Lineker Media (GLM), not a personal service company.

GLM is a general partnership between the Lineker and his ex-wife Danielle (now known as Ms Bux), and it is governed by the Partnership Act 1890.

Disputed points 

The issues to discuss at the tribunal were: 

  1. whether IR35 applies to arrangements involving the supply of an individual’s services to a client through a partnership governed by the Partnership Act 1890 in which the individual is a partner
  2. whether GLM was a partnership
  3. whether there was a direct contract between the BBC and/or BT Sport, Lineker and Ms Bux, and 
  4. whether the appellants should be prevented by estoppel from contending that there was no valid partnership. 

Partnership agreement

Lineker and Bux signed a partnership agreement in 2012, and they clearly both worked in the business. Although Bux received £30,000 per year for her work irrespective of the profits of the business, the FTT decided that GLM was a general partnership, as defined by the 1890 Partnership Act. Also, because there was a genuine partnership the issue of estoppel did not arise.

Partnership accounts in the name of GLM were drawn up by chartered accountants for the years ended 31 July 2014 to 2018, and partnership tax returns were submitted for those tax years which identified Lineker and Bux as partners. The judge noted that Lineker paid income tax and class 4 NIC on the entirety of the income from his services for the tax years in question, less £30,000 per year paid to Bux, which she also paid tax on. 

Partnership as an intermediary

This was a key part of this case as, according to IR35 expert David Kirk, this is the first time that the IR35 legislation has been tested where the intermediary is a general partnership.

The FTT examined the wording of ITEPA 2023, s52 which sets out the conditions of liability to the IR35 provisions where the intermediary is a partnership, and ITTOIA 20025, s164 which provides the special rules for partnerships where payments may be treated as employment income under the IR35 legislation. The judge decided that IR35 can apply where an individual’s services are supplied to a client through a partnership.

If IR35 does apply, the worker (Lineker in this case) is treated as having been employed by the partnership and having received a deemed employment payment as taxable earnings. The partnership would be liable to pay employer’s class 1 NIC on those deemed earnings. Hence the “avoided tax” in this case is purely class 1 NIC potentially payable by the deemed employee and employer. 

Direct contract 

The case turned on whether there was, from a legal perspective, a direct contract between Lineker and his customers: the BBC and BT Sport. The key clause is ITEPA 2003 s49(1)(b) which envisages a binary choice – either there is a direct contract between the client and the worker or there is not, and the IR35 provisions can only apply where there is not a direct contract. 

The judge went back to the 1890 Partnership Act to determine that each partner acts as both a principal and as an agent to bind the firm. Thus, as a matter of law when Lineker signed the contracts with the BBC and BT Sport, he signed as a principal, thereby directly contracting with those bodies. 

Kirk explained that a general partnership has no legal personality, unlike an LLP, limited partnership or Scottish partnership. 

Kirk commented: “The judge is implying that ITEPA 2003 s52 can only apply for an LLP or limited partnership, or in the case of a general partnership (that is, a partnership formed under the Partnership Act 1890) where the worker is not one of the partners.

“There may be an intermediary in this relationship between Lineker (the worker) and the BBC/ BT Sport (the client) but there is also a direct contract between worker and the client, so because that exists ITEPA, s49 (1)(b) does not apply.” 

Possible rematch 

Kirk commented: “This is a very legalistic judgment, and it could be open to appeal, as another judge may well come to a different conclusion.”

The Financial Times has quoted an HMRC spokesperson as saying: “We do not agree with its decision that the [IR35] rules cannot apply in this case and we’re considering an appeal.”

Replies (65)

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By Justin Bryant
29th Mar 2023 12:35

I cannot see anything wrong with this FTT decision (HMRC never complain when they win on a technicality do they?). See also: https://www.accountingweb.co.uk/any-answers/gazza-wins-match-of-the-day

HMRC are just massive bad losers (not to mention massive wasters of taxpayers' money) and well done to the judge here - after all, it's not his job to fix defective/misfiring legislation per para 32 et seq here: https://www.bailii.org/ew/cases/EWCA/Civ/2022/33.html .

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By Ruddles
29th Mar 2023 12:53

"The judge is implying that ITEPA 2003 s52 can only apply ... in the case of a general partnership (that is, a partnership formed under the Partnership Act 1890) where the worker is not one of the partners."

I don't think that is quite correct - Gary escaped only because it was himself that signed the contract. Had the contract been made with another partner (ie his wife at the time) then the partnership would have been caught. (para 94)

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Replying to Ruddles:
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By Justin Bryant
29th Mar 2023 13:08

That's right (I saw that error too but was too polite to point it out). (Possibly he's not that great an IR35 expert and I'm not sure why Aweb doesn't interview people like us for our erudite (or perhaps just plain rude) comments.)

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By RFL H
29th Mar 2023 12:58

Perhaps HMRC could explain how many further cases they have with partnerships before wasting more of our money on a pointless appeal?

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By nick farrow
29th Mar 2023 13:03

Is the implication here that had Gary been contracted via a PSC, he would have been caught by IR35?

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Replying to nick farrow:
By Ruddles
29th Mar 2023 13:07

Yes

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Replying to nick farrow:
Head of woman
By Rebecca Cave
29th Mar 2023 13:16

No. The hypotectical contract between Lineker and his suppliers was not tested, as a real direct contract existed. So we don't know whether he would have been caught by IR35 if the GLM partnership had been a company.

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Replying to Rebecca Cave:
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By Justin Bryant
29th Mar 2023 13:18

That's right. Per my comments in the above link, this should have alternatively been assessed and litigated by HMRC as a simple (non-IR35) self-employment vs. employment case. They should be rightly embarrassed.

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Replying to Justin Bryant:
By Ruddles
29th Mar 2023 13:33

But that is said only with the benefit of hindsight. If HMRC believed (rightly or wrongly, we will need to wait and see if there is an appeal) that the arrangement was within the scope of IR35 it would have been inappropriate to pursue it as a self-employment v employment case.

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Replying to Ruddles:
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By Justin Bryant
29th Mar 2023 14:03

I disagree. As indicated by GL's barrister, this was a dumb HMRC oversight (and I think they know it, given their bad loser attitude here and if they don't know it already he can probably tell them himself as he acts for HMRC occasionally I believe).

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Replying to Justin Bryant:
By Ruddles
29th Mar 2023 14:19

That is of course merely the view of the barrister and the basis on which his case was put. Doesn't mean that he is right and doesn't mean that the decision won't be reversed if appealed.

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Replying to Justin Bryant:
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By Justin Bryant
04th Apr 2023 13:15

Looks like HMRC have learned their lesson here:

"We expect HMRC to be sending out Regulation 80 determinations for the loan charge to employers shortly. As part of this exercise, they are also sending out discovery assessments to individuals which will include the underlying loan charge tax liability (in case they can’t collect it from the employer) and the s222 charge, where it applies."

https://www.litrg.org.uk/latest-news/news/230403-loan-charge-and-section...

L

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Replying to Rebecca Cave:
By Ruddles
29th Mar 2023 13:30

Agreed. I should have qualified my "no" by saying that had it been found that IR35 would have applied had the contract been made by someone else then it follows that it would also have applied in the case of a PSC. But as you say, the hypothetical contract was not examined.

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By Hugo Fair
29th Mar 2023 14:58

Not as important as the central issue being discussed by Justin and Ruddles, but ...

"(Linekar) was temporarily suspended from the BBC for making what some people viewed as an impartial political remark on Twitter"
Really? Impartial? It was the very lack of his impartiality that was the bone of contention.

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Replying to Hugo Fair:
By Ruddles
29th Mar 2023 15:29

Impartiality is in the eye of the beholder. I don't recall anything remotely political in GL's tweet. Because he was criticising the words of a Government Minister he has been seen to be critical of the Government. However, there is nothing to suggest that he would not have said exactly the same thing had the words been uttered by any other politician.

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Replying to Ruddles:
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By Hugo Fair
29th Mar 2023 16:10

Strangely my comment was intended to be impartial (with regard to Lineker).

But I disagree that "Impartiality is in the eye of the beholder" ... according to what I was taught it means 'treating all rivals or disputants equally'.
And the example in the dictionary has "the minister cannot be impartial in the way that a judge would be".

Lineker is entitled to his opinion on the statements/actions of any politician (whether or not he should then broadcast it is a contractual matter between him and the BBC), but what he tweeted was *not* an example of impartiality.

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Replying to Hugo Fair:
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By Justin Bryant
29th Mar 2023 16:21

Haven't you heard? Britain has been totally dumbed down. You basically only need to watch any TV programme or read any newspaper (or read the moronic posts/comments here) to see that.

That kind of bad English is so commonplace I barley bat an eyelid these days.

(NB that's obviously a pretty predictable joke above for any smart alecks out there.)

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Replying to Justin Bryant:
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By Beef curtains
01st Apr 2023 20:16

Bet you didn't mean to spell "barely" as "barley", or is that just commonplace, bad English . Jonely oking.

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Replying to Beef curtains:
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By johnjenkins
03rd Apr 2023 10:43

Wheat a minute, that's amazing.

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Replying to Hugo Fair:
By Ruddles
29th Mar 2023 16:43

By definition, then, having an opinion about anything makes one partial.

But which rivals or disputants did Mr L not treat equally in his tweet? (Bearing in mind that what we are discussing is political impartiality)

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Replying to Ruddles:
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By Justin Bryant
29th Mar 2023 16:57

No. You can obviously have an impartial opinion (broke my non-eyelid batting habit there). Like referees do, day in, day out, in footie games re their penalty opinion decisions etc. (some might argue with that obviously), as GL himself could tell you.

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Replying to Justin Bryant:
By Ruddles
29th Mar 2023 17:09

That was my point (obviously) - GL was merely expressing an opinion, which in my view was free of any political bias.

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Replying to Ruddles:
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By Hugo Fair
29th Mar 2023 17:39

You're opening up a potentially interesting avenue for philological investigation ... can one acknowledge one's own bias (which everyone has to varying degrees on different topics) and yet remain impartial when proffering an opinion?

Although I was attempting to avoid getting drawn into the political vortex, you're right that in this specific case the question was one of political impartiality (or not) - in the eyes of the BBC.
I don't work for them (and cannot imagine a worse fate than to do so), but it is I believe part of their constitution as a publicly-funded broadcaster to remain politically impartial ... and hence there are strict guidelines for presenters.

Based purely on observation, this is generally achieved via one of two routes:
1. Presenter voices no opinions but elicits them from 3rd-parties who are carefully chosen to represent the spectrum of possible opinions on the matter;
2. Presenter voices an opinion, but couches it in terms that associate it with an absent 3rd-party AND then adds "but others say that .." (or some such).

They are also forbidden from making incendiary comments (I'm not sure of the exact terminology but it is akin to the 'hate speech' laws) - which some might feel would include describing anyone (Tory Home Sec or Labour Leader or neighbour) as using language similar to that found during the rise of Nazism in Germany.

Lest we forget, I have no opinion on Gary's opinions (and only the BBC and retained lawyers have a relevant view on his right to express them whilst under contract) ... but, going back to the start, I don't believe it's correct to describe his tweets as impartial (and I doubt he thinks of them in that way himself).

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Replying to Hugo Fair:
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By More unearned luck
29th Mar 2023 20:11

I think you misrepresent the position at 2, Hugo. When presenters interview a government minister they put to him or her the points that the opposition would make and when they interview a shadow minister they put to him or her the points that the government make. Neither sets of points are necessarily the presenters own.

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Replying to More unearned luck:
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By raybackler
31st Mar 2023 10:03

What you have described is Hugo's point 1.

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Replying to Hugo Fair:
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By More unearned luck
29th Mar 2023 20:25

One of the arguments deployed by GL's defenders in the recent row was that he's not a BBC staff member but is an independent contractor. On Justin's view he is, indeed, a BBC (and BT Sport) employee. But, of course, a 'direct contract' can be one for services or one of service. Which it is wasn't tested.

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Replying to More unearned luck:
By Ruddles
29th Mar 2023 21:02

To defend Justin, which may seem odd, I don’t think that is his view at all. Rather, he was simply saying that if there is a direct contract then HMRC would have been better advised to go down a different path. I don’t see anything from him indicating whether he thinks they would have been successful.

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Replying to Ruddles:
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By Justin Bryant
31st Mar 2023 08:40

That's right that's it odd you defending me as you are almost always wrong about everything, but you are basically right on this occasion, except I think HMRC could have made an IR35 protective assessment against GL in the alternative (and have that stayed behind the other ones). NB the IR35 deemed contract is not necessarily the same as the actual one, so all else being equal HMRC usually have better prospects under IR35 than normal (non-IR35) employment vs. self-employment tax litigation and they may explain things here.

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Replying to Justin Bryant:
By Ruddles
31st Mar 2023 09:51

You only think that I (and others) are wrong about "everything" is because we frequently have a different opinion from yours and that, because you think that you are so bright and clever, you must be right about everything. Well, I have news for you ...

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Replying to Hugo Fair:
By Duggimon
31st Mar 2023 10:17

Hugo Fair wrote:

They are also forbidden from making incendiary comments (I'm not sure of the exact terminology but it is akin to the 'hate speech' laws) - which some might feel would include describing anyone (Tory Home Sec or Labour Leader or neighbour) as using language similar to that found during the rise of Nazism in Germany.

If the language used by Ms Braverman was indeed comparable in a number of ways to the government propaganda, of which we have extensive records, in 1930s Germany - and I mean irrefutably comparable, similar in a number of ways - would you still assert that mentioning this, without any call to action or greater condemnation than reference to the language itself is expressing a partial opinion?

I think the point I and others are making is that Linekar's comments are only politically partial if he made them with political intent or because of political views. If instead it was out of abhorrence of the specific statements he was responding to then it's merely an opinion, not a political opinion, and cannot prejudice the BBC's political impartiality. Their presenters are allowed opinions on all sorts of things and to express them freely, it's political bias that is the issue.

And of course, if it's simply a statement of fact then it's not an opinion at all, and it's very hard to refute the content of what he said.

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Replying to Hugo Fair:
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By graydjames
31st Mar 2023 10:48

Hugo Fair wrote:

"Although I was attempting to avoid getting drawn into the political vortex...."

Why did you post then? Your comment was overtly political and you must have known it would draw comment. Incendiary language using provocative words like "invasion" and "removals" and reference to 100m wanting to come to the UK is wholly typical of the language used the far right in the early years of the NSDAP.

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Replying to graydjames:
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By Hugo Fair
31st Mar 2023 12:29

You really must learn to read more carefully before either wrongly accusing others or repudiating things not said.

I defy you to quote anything I've said on this thread that "was overtly political" - and my comment that you DO quote is precisely about trying to *avoid* others (like you apparently) converting any mention of partiality into an automatic correlation with politics. Doing so is either lazy or deliberately disingenuous.

You ask 'why did I post .. you must have known it would draw comment?'
I did indeed know (or at least hope) that it would draw comment ... that is after all the primary purpose of a public forum (to exchange views and hold somewhat stilted 'conversations' on topics of interest).

It's a shame that you appear to have a closed mind ... else we could have had an interesting discussion about the (mis)use of words like 'invasion', which have been (and continue to be) used inappropriately by Russia, China, Israel, Greek Cyprus, Burma and countless others (not just Ms Braverman or the NSDAP as was).

My point, which you've simultaneously undermined and proven, was that it is not necessary to automatically equate any partiality as deriving solely from a political standpoint.

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Replying to Hugo Fair:
John Hextall
By John Hextall
31st Mar 2023 11:00

I think what Lineker said was a statement of fact that was rightly critical of the government and, in itself, impartial. The response of the BBC was heavily in favour of the government rather than the truth and was, in my opinion, rather less impartial than it should have been.

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Replying to Hugo Fair:
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By graydjames
31st Mar 2023 10:36

Hugo Fair wrote:

Not as important as the central issue being discussed by Justin and Ruddles, but ...

"(Linekar) was temporarily suspended from the BBC for making what some people viewed as an impartial political remark on Twitter"
Really? Impartial? It was the very lack of his impartiality that was the bone of contention.

I wondered how many posts there would be before someone found an excuse to turn this IR35 issue into yet another attack on Lineker over the wholly unrelated issue of his Twitter post. Not many, as expected.

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Replying to graydjames:
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By Hugo Fair
31st Mar 2023 12:41

"I wondered how many posts there would be before someone found an excuse to turn this IR35 issue into yet another attack on Lineker over the wholly unrelated issue of his Twitter post."

I repeat my earlier comment ... please read more carefully before making veiled accusations.
The quote (referencing Lineker's thoughts on Twitter) in my post was an extract from the main article - NOT me introducing the topic.
So, whatever your opinions on all the various aspects of the case, if anyone "found an excuse" to 'connect' the two things then it was the author of the article (who seems to have been making a minor political point gratuitously - but one with which you agree, so that's alright then)!

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By Ian McTernan CTA
29th Mar 2023 15:45

So Lineker is now 1-1 on his tax affairs (I seem to recall he previously got caught and had to pay a huge sum).

HMRC pressing for extra time...

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Replying to Ian McTernan CTA:
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By AndrewV12
31st Mar 2023 10:21

Lets hope it does not go to penalties.

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By AndrewV12
31st Mar 2023 10:20

'Partnership agreement
Lineker and Bux signed a partnership agreement in 2012, and they clearly both worked in the business. Although Bux received £30,000 per year for her work irrespective of the profits of the business, the FTT decided that GLM was a general partnership, as defined by the 1890 Partnership Act. Also, because there was a genuine partnership the issue of estoppel did not arise.'

It just shows you, do your homework before you start working freelance (providing the personal services of Gary Lineker) and you can side step quite a bit, it amazes me of all those who cannot get the basics right before working freelance (offering their services).

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Replying to AndrewV12:
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By johnjenkins
31st Mar 2023 11:37

Andrew, you shouldn't have to seek loopholes in order to bypass IR35, although I know you do have to. It really is time that IR35 was put out to pasture together with MTD. Look at all the controversy and time wasting these have caused, not only for Accountants but for Government and HMRC as well.

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By DMBAcc
31st Mar 2023 10:33

Gosh wouldn't we all like to be in the position of HMRC officials "considering an appeal". I wonder if they would be so quick to respond if the costs came out of their own pockets! Does anyone ever complete cost benefit analysis on these folk. And whilst on this subject how about they spend their time getting the billions back from COVID fraudsters they appear too tired and disinterested to chase. What DO they do with their time?

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By Nebs
31st Mar 2023 11:06

To show that there are no hard feelings, HMRC have agreed to pay for Gary Lineker to go on a skiing holiday with Gwyneth Paltrow and Terry Sanderson.

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By richards1
31st Mar 2023 11:17

Irrespective of the technical arguments it would be interesting to see Linekers effective tax rate. That would put the lie under the political spoutings this individual makes. For sure he won’t be paying the tax rate of mere mortals.

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Replying to richards1:
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By RogerMT
31st Mar 2023 11:48

Lineker is one of the more conscionable millionaires on this benighted island, in that he willingly pays Class 4 NIC as well as top rate tax on his earnings. His marginal rates will probably be a lot more than most of his fellow millionaires, Tory MPs included.

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By richards1
31st Mar 2023 11:17

Irrespective of the technical arguments it would be interesting to see Linekers effective tax rate. That would put the lie under the political spoutings this individual makes. For sure he won’t be paying the tax rate of mere mortals.

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By Mallock
31st Mar 2023 11:37

I was surprised when I saw that HMRC had taken a case against a partnership under IR35 but had they taken an employment v self employment case and won, it would have been the BBC who would have been liable for the tax, NI and penalties. I can't help but think that there is a desire at some high level to avoid the BBC being subject to any public humiliation (although it manages to do that for itself sometimes)
As mentioned earlier I would like to see some cost/benefit analysis of the appeals HMRC funds using our money. In fact I would like to see a proper cost/benefit analysis of the whole IR35 regime. Clients of ours working through PSC's in the public sector getting paid perhaps £80K/£90K are now employed in the public sector, with funded pensions, paid holiday and sick pay on salaries of £120K - £140K doing the same job. Is this net additional cost taken in to account in HMRC's calculations of the benefits of IR35?
Most of our private sector PSC clients were highly specialised experts but due to a blanket approach by the agencies they obtained work from found they couldn't work outside IR35 despite genuinely being outside IR35 - some have taken their skills overseas and others have retired costing the country a huge loss of skills. With dividend tax and higher Corporation Tax Rates is there any positive benefit from IR35? I doubt it.

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By AmandaElliott
31st Mar 2023 11:43

Beaten the BBC and HMRC - he’s going to be unbearable now……

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By rmillaree
31st Mar 2023 12:25

If this was a close call i thinkm mr lLneker can count himself a very lucky boy

"Mr Lineker wrote on social media: "I had already paid all tax due at the top rate and happily so. I'm totally flabbergasted as to why I was expected to pay double. Thankfully justice was done.""

Would others agree that his direct quote here is more than slightly misleading to members of the
general public who would view the sum of tax and ni as being the "overall tax" - the reality here appears to be that he has significanly saved on national insurance that he would have paid had this contract been caught by IR35 - presumably there are other peeps who work for the bbc who have been clobbered have paid signficantly more overall tax than Mr Gary. Also why does he think he would be double paying tax ?

At present his reputation probably remains intact - but if there is doubt as to whether he would win an appeal perhaps he is not fully out of the woods. Either way his clever use of the word tax whilst ignoring ni seems to slightly irk me from a tyransparency viewpoint - he didnt have to comment on his taxes but he did !.

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Replying to rmillaree:
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By richards1
31st Mar 2023 13:02

Well he is an ex footballer and perhaps not as well endowed cerebrally as the general population

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Replying to rmillaree:
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By richards1
31st Mar 2023 13:02

Well he is an ex footballer and perhaps not as well endowed cerebrally as the general population

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Replying to rmillaree:
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By Mallock
31st Mar 2023 13:25

rmillaree wrote:

If this was a close call i thinkm mr lLneker can count himself a very lucky boy

"Mr Lineker wrote on social media: "I had already paid all tax due at the top rate and happily so. I'm totally flabbergasted as to why I was expected to pay double. Thankfully justice was done.""

Would others agree that his direct quote here is more than slightly misleading to members of the
general public who would view the sum of tax and ni as being the "overall tax" - the reality here appears to be that he has significanly saved on national insurance that he would have paid had this contract been caught by IR35 - presumably there are other peeps who work for the bbc who have been clobbered have paid signficantly more overall tax than Mr Gary. Also why does he think he would be double paying tax ?

At present his reputation probably remains intact - but if there is doubt as to whether he would win an appeal perhaps he is not fully out of the woods. Either way his clever use of the word tax whilst ignoring ni seems to slightly irk me from a tyransparency viewpoint - he didnt have to comment on his taxes but he did !.

I don't think his quote is misleading at all. He will have paid virtually the same NI as anyone else who was employed or self employed earning the same amount of money. The NI that HMRC would like him to have paid was employer's NI which by it's very definition should be paid by employers not employees.
If anyone was due to pay employer's NI it was the BBC.

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