In Gary Lineker & Danielle Bux t/a Gary Lineker Media v HMRC [2023] TC8774, HMRC incorrectly challenged broadcaster Gary Lineker's contract with the BBC and BT. It lost a tax appeal against assessments for £4.9m. The First Tier Tribunal (FTT) found that while partnerships can be subject to IR35, the intermediaries' legislation, those rules did not apply as Mr Lineker had contracted with the Broadcasters personally.