Former Manchester United and England captain Bryan Robson has lost his most of his IR35 tax case against HMRC as the Tribunal found he was an ‘employee’ in his ambassadorial role at his former club.

Robson has been paid £150,000 every six months to be an ambassador of the Red Devils, a role he has held since 2008.

He has the obligation to make a minimum of 35 personal appearances at functions and events.

His personal services company, known as Bryan Robson Limited, issued an appeal to the First-Tier Tribunal after HMRC took the view he provided services to Manchester United in a way that reflected employment and not self-employment.

HMRC took the view that his tax bill belonged inside the scope of the IR35 legislation.

IR35 refers to legislation designed to ensure that workers who are essentially employees pay the same income tax and National Insurance contributions as direct employees.

It was noted that Robson was economically dependent on his former football team, which made up 87 per cent of his income (£171,000) in the 2019/20 tax year and 94 per cent of his income (£319,000) in the ‘20/21 tax year.

HMRC believe he should have paid his National Insurance contribution (NIC) and PAYE between December 2019 to April 2021.

However, that amount was not disclosed due to the fact HMRC included a separate income he received through image rights within its calculations.