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Offside! Famous footballer falls foul of IR35 rules

Shared from Tax Insider: Offside! Famous footballer falls foul of IR35 rules
By Richard Curtis, April 2025

Richard Curtis reviews the recent case of Robson v Revenue and Customs on employment status. 

Football supporters of a certain age will be familiar with the name of Bryan Robson, particularly the important part he played between 1981 and 1994 in the success of Manchester United Football Club (MUFC).  

Some years after he finished playing, Mr Robson became an ‘ambassador’ for MUFC. At first, the agreements to carry out this work – personal appearances – and for the use of his image rights were between the club and Mr Robson personally; but from December 2019, the agreement was between MUFC and his personal company, Bryan Robson Limited (BRL). 

HM Revenue and Customs (HMRC) took the view that the payments from MUFC to RBL were from a disguised employment and within the ‘off-payroll working’ rules. Often known as ‘IR35’, these rules seek to ensure that a worker or

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