28 February 2018 
Michael Edwards,
No doubt most members will have noticed the media interest in the First-Tier tribunal appeal relating to the case of Christa Ackroyd Media Ltd v HMRC. This is a case where HMRC had contended that the IR35 regulations should apply to payments made to the company by the BBC. The Tribunal dismissed the company's appeal against this contention. A copy of a decision can be accessed here. One of the things that is interesting about it is the Tribunal’s explanation of how it reached its decision, which includes a useful summary of the previous tax cases that informed that decision - in particular, paras 130 to 180. Finally, it is instructive that at para 180, in its conclusion, the Tribunal say this:
“We acknowledge that this is a value judgement. It is in the nature of a value judgement that different people may come to different conclusions…….”
To quote the Bard, “ay, there’s the rub!”
