Collingwood v Revenue and Customs (INCOME TAX - payments received from sponsorship agreements reported through Appellant's company - assignment of intellectual property rights between the Appellant and his company - the absence of the concept of "Image Rights" under English law) [2025] UKFTT 1065 (TC) (28 August 2025)

Parties

Procedural Posture

Income Tax Appeal / Final Judgment on Appeal Against Closure Notices

Legal Issues

1. 1 Whether the Appellant is liable to income tax on payments received from sponsorship agreements under ss 5, 8, or 687 ITTOIA 2005
2. 2 Whether the Appellant had a legitimate expectation that HMRC would not amend his tax returns based on prior treatment
3. 3 Whether the Tribunal has jurisdiction to consider public law arguments in this appeal

Ratio Decidendi

The Appellant is liable to income tax on the sponsorship payments because the agreements were made with him personally, and he was the person entitled to the profits. The Assignment Agreement only assigned intellectual property rights and did not transfer the right to provide personal services or appearances. English law does not recognise image rights as a separate asset class. The Tribunal has no jurisdiction to consider legitimate expectation arguments in this context.

Court Disposition

Appeal dismissed

Orders

• The Appellant is liable to income tax on the sponsorship payments for the tax years 2011-12, 2012-13, 2013-14, and 2015-16.
• Closure notices issued by HMRC stand good and amendments to self-assessment returns are upheld.