The Upper Tribunal could find no material error of law in the First-tier Tribunal’s decision that payments by Sky for the services of a football pundit through his personal service company were liable to income tax and National Insurance contributions under the intermediaries (IR35) legislation. 

Summary 

The Upper Tribunal (UT) could find no material error of law in the First-tier Tribunal’s (FTT’s) decision that payments by Sky for the services of a football pundit through his personal service company were liable to income tax and National Insurance contributions (NICs) under the intermediaries (IR35) legislation. 

Background 

Between 1994 and 1998, an ex-footballer (PT) appeared on Sky in Soccer Saturday. He returned to the programme in 2004. The appellant company was incorporated in January 2013, with the intention that PT’s services for Sky be