The intermediaries legislation (IR35) applied to the services of a well-known TV and radio presenter, which were provided through a personal service company. 

Summary 

The intermediaries legislation (IR35) applied to the services of a well-known TV and radio presenter, which were provided through a personal service company. 

Background 

The appellant company was incorporated on 26 April 2001, with the sole director (EH) being the majority shareholder and his children owning the remaining shares. EH was a well-known journalist and broadcaster. During the tax years 2011/12 to 2014/15, the appellant entered into four contracts with ITV for the provision of EH’s services as a presenter of ‘This Morning’. Each contract was for a period of approximately one year, with short gaps in between. HM Revenue and Customs (HMRC) issued determinations and notices to the