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FTT (Tax) in Bryan Robson Ltd v HMRC: image rights outside IR35; ambassadorial appearances deemed employment

Published on: 28 January 2025

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Bryan Robson Ltd v HMRC [2025] UKFTT 56 (TC)

Bryan Robson Ltd functioned as the personal service company for the former Manchester United and England footballer, Bryan Robson. For many years he served as club ambassador under a succession of agreements. It was accepted before the FTT that the only issue in dispute concerned the 2019 agreement between the club and the company; earlier deals had been made between the club and Mr Robson personally. Under the 2019 agreement, the club was granted a licence to use and exploit Mr Robson’s image worldwide, for any purpose. The agreement also obliged the company to ensure that Mr Robson undertook personal appearances on no fewer than 35 days in each six‑month period. These duties covered hosting at matches and attending events held by the club’s sponsors. The company was paid a flat fee. The company’s initial case was that the agreement should properly be characterised as an image rights agreement and therefore fell wholly outside IR35...

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