Robson, 68, acts as an ambassador for his old club, where he played from 1981 to 1994, and earns an annual fee of up to £300,000 for the work, which gave the club ownership of his image rights and prevented him from entering any endorsement agreements without their permission.

The ambassador role involved a minimum of 70 appearances a year, which had to be more than four hours in duration, and he was paid travel and hotel expenses as required by the club. They also determine when and where he appeared, raising the spectre of mutuality of obligation.  

Throughout the period under appeal from 2015 to 2021, he submitted tax returns through his personal services company Bryan Robson Ltd.