Atholl House Productions v HMRC

In Atholl House Productions v HMRC [2019] UKFTT 242 (11 April 2019) the FTT found that no employment relationship existed.

Atholl was the personal service company of Ms Adams who performed services for the BBC and other media organisations. She had appeared in various TV programmes and wrote columns for newspapers and magazines. She also worked in the corporate sector and had co-written a book.

During the relevant two years Ms Adams presented a programme on BBC Radio Scotland called ‘The Kaye Adams Programme’. The show ran for three hours on each weekday morning. Ms Adams’ services were provided under two agreements between the BBC and Atholl. The issue was whether if the services supplied by Ms Adams to the BBC had been supplied under a contract directly between Ms Adams and the BBC she would have been regarded for income tax purposes as an...