Paul Collingwood, the former England batsman and professional cricketer for Durham County Cricket Club for over 20 years, went to the First Tier Tribunal to appeal four closure notices totalling £196,187.09 issued by HMRC in December 2019 related to four tax years starting in 2011-12.

The dispute centred around the use of Collingwood’s personal services company, PDC Rights Limited to handle sponsorship earnings, and the correct tax treatment of various payments received from sponsorship contracts with Slazenger, the Professional Cricketers’ Association (PCA) ambassador programme and Clydesdale Bank.

In an agreement dated 21 January 2005 between the appellant and PDC Rights, Collingwood assign his intellectual property rights, and any analogous intangible rights, to the personal services company in an assignment agreement.