Stuart Barnes was working as a commentator for Sky through his personal services company, S&L Barnes Ltd (SLB).

HMRC opened an investigation into his tax affairs and determined that income tax and national insurance contributions were due on the earnings from his Sky contract.

The principal issue in this appeal is whether on the facts, the IR35 intermediaries legislation applied to the contractual relationship between Barnes, SLB and Sky.

If the legislation applied, then tax liabilities to income tax and national insurance contributions arise for SLB.

The overall amount under appeal is £695,461.97 (not including interest), and relates to five tax years from 2013 to 2019.

During those years, Barnes had a number of income streams, including work for the Times and Sunday Times, as well as the Sky contract.