Sprinkling of gold dust: Tax implications of Bryan Robson’s ambassador agreements

Bryan Robson, a former footballer who needs no introduction, established a personal services company, Bryan Robson Limited (BRL), in 1981, early in his career at Manchester United Football Club (MUFC). After the end of his playing career, Robson served as an ambassador for MUFC through various agreements, commencing in 2008. In a recent case at the First-tier Tax Tribunal^[1], the tax implications of these agreements have been explored.

While Mr Robson is far from the first sports personality to face HMRC’s questioning of their tax affairs in connection with what is known as IR35 (explained below), this is the first time that a tribunal has considered the use of image rights in that context. Although agreements of this kind are particularly common in the context of football, the principles regarding image rights are applicable across all sports.

This article examines the potential tax implications of the decision as it relates to ambassador agreements and any image rights payments contained therein, looking at:

• What is an ambassador agreement?
• Mr Robson’s ambassador agreements
• HMRC's assessments of Mr Robson’s agreements
• The ‘IR35’ regime (off-payroll working)
• How do image rights interact with IR35?
• Analysis
• Key lessons for current and former sports stars and clubs