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Hypothetical contract would be one of service

08 November 2021
Issue: 4816 / Categories: Tax cases
Little Piece of Paradise Ltd (TC8300)  

In July 1988 Mr C a sports presenter and commentator started working for British Sky Broadcasting Ltd which changed its name to Sky TV Ltd in February 2015. He initially undertook work with Sky on a self-employed basis but in June 2003 at the request of Sky he provided his services through his personal service company - Little Piece of Paradise Ltd (LPPL).

A dispute arose as to whether on the facts the intermediaries legislation – IR35 - applied to the relationship between Mr C LPPL and Sky. For the duration of the contracts in question Mr C was the lead presenter for the Professional Darts Corporation (PDC) events covered by Sky.

Mr C said he undertook the same work through his company as he had when self-employed. The work arrangements did not change and he was not bound into the organisation...

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