A football pundit and co-commentator would have been an employee of British Sky Broadcasting Ltd under a hypothetical contract, and payments made to his personal service company were therefore subject to the intermediaries (IR35) provisions.  

Summary 

A football pundit and co-commentator would have been an employee of British Sky Broadcasting Ltd (Sky) under a hypothetical contract, and payments made to his personal service company were therefore subject to the intermediaries (IR35) provisions. 

Background 

A company (MML) was the personal service company of a former Scottish Premiership footballer (NM) who played international football for Scotland, and later became a qualified coach. After retiring as a player, he moved into punditry. NM and his wife formed MML in August 2009. 

MML entered into two service agreements with Sky, dated 2 May 2012 and 18