A Freedom of Information request reveals a dramatic 73% decline in the use of HMRC's CEST tool since 2021-22, raising doubts about its reliability.
Thompson's case serves as a stark warning for freelancers and businesses alike. With HMRC ramping up its focus on IR35 enforcement, thorough contract reviews and clear working practices are essential to mitigating tax risks.
Dave Chaplin, CEO of IR35 compliance firm IR35 Shield, explained the complexities of the case, emphasizing that Lineker operated through a general partnership structure. This led to him being subject to income tax similar to that of a sole trader. Chaplin stated, 'Almost all income tax was already paid upfront,' and noted Lineker also contributed both employer and employee National Insurance Contributions due to this partnership arrangement. This context highlights that his tax obligations were already substantial, raising questions about the appeal.
