- Purposive interpretations: the impact of fresh guidance.
- HMRC enquiries: disclosure information and reasons behind decisions.
- Sale of goodwill: capital gains tax implications.
It may not have escaped anybody’s attention that HMRC are seeking to crack down on the use of personal service companies and to extend the reach of the well-known IR35 rules.
HMRC has had mixed success in the courts in seeking to apply these rules against people in the media, particularly TV presenters; the cases of Christa Ackroyd and Lorraine Kelly spring immediately to mind (Christa Ackroyd Media Ltd v Revenue and Customs Commissioners 2019 UKUT 0326; Albatel Ltd v Revenue and Customs Commissioners [2019] UKFTT 195 (TC)). However, there are many others, such as the more recent decision in Kickabout Productions Ltd v Revenue and Customs Commissioners [2019] UKFTT 415 (TC), [2019] SWTI 1363 involving a Mr Paul Hawksbee who broadcasted on TalkSport, where the arrangements were found not to be within IR35.
We
