A radio presenter would have been an employee of the radio station under a hypothetical contract, and payments made to his personal service company were therefore subject to the intermediaries (‘IR35’) provisions.  

Summary 

A radio presenter would have been an employee of the radio station under a hypothetical contract, and payments made to his personal service company were therefore subject to the intermediaries (‘IR35’) provisions.

Background 

The respondent company (‘KPL’) was the personal service company of a radio presenter (PH), who had co-presented a show on Talksport for many years. For the three tax years under appeal (2012/13 to 2014/15) the income that PH (through KPL) obtained from Talksport was approximately 90% of his total income for those.&