Part of the consideration under a contract between a football club and a personal services company for the provision of services by an ex-player was outside the scope of the intermediaries (IR35) legislation as it related to image rights, but the balance of the consideration was employment income.  

Summary 

Part of the consideration under a contract between a football club and a personal services company (PSC) for the provision of services by an ex-player was outside the scope of the intermediaries (IR35) legislation as it related to image rights, but the balance of the consideration was employment income. 

Background 

The appellant was the PSC of an ex-professional footballer (BR), who acted as an ambassador for one of his former clubs (MUFC) for many years. HM Revenue and Customs (HMRC) made determinations under the PAYE regulations (SI 2003/2682, reg 80) and NICs