A TV and radio presenter who provided his services through a personal service company would not, had those services been provided under contracts directly between ITV/BBC and the presenter, be regarded for income tax purposes as an employee of ITV/BBC.

Background

A television and radio presenter, Adrian Chiles (AC), set up the appellant (BBL), a personal service company (PSC). During the period 6 April 2012 to 5 April 2017, BBL provided AC’s services pursuant to two ITV contracts and three BBC contracts in addition to other work for other parties.

HM