TC09624 - [2025] UKFTT 01065 (TC)

The Appellant entered into various PCA Ambassador Agreements with PCA. The substance of these agreements was recorded in letters addressed to the Appellant, personally.

On 20 December 2011, PCA entered into a PCA Ambassador Agreement with the Appellant, whereby the Appellant was engaged to undertake six PCA Ambassador appearances in 2012, at an agreed fee of £8,400. Payment would be made by a monthly bank transfer of £1,050, starting 20 May 2012; with a final payment on 20 December 2012, subject to the receipt of invoices. The fees were paid gross and required the Appellant to declare the sums on his self-assessment tax return.

On 22 January 2013, PCA entered into a PCA Ambassador Agreement with the Appellant, and confirmed that they would cover the cost of his Jaguar for its nine-month lease period, including insurance and any approved expenses. In return, the Appellant was required to take part in six PCA Ambassador appearances.

On 18 June 2014, PCA entered into another PCA Ambassador Agreement with the Appellant, confirming his appearances in 2014. Once again, PCA noted that the Appellant was required to undertake six PCA Ambassador appearances and, in return, he would receive a total fee of £6,000. Accommodation was to be booked and paid for by the PCA but all other expenses had to be agreed in advance.

Payment would be made by six bank transfers in the sum of £1,000. PCA would cover the cost of the Appellant’s “Loch Lomond” membership for 2014 to enable him to host the PCA’s trip to the club.

On 16 December 2014, PCA entered into a further PCA Ambassador Agreement with the Appellant, confirming his appearances for 2015. They noted that he was required to undertake six PCA Ambassador appearances and in return he would receive a total fee of £6,000. Accommodation was to be booked and paid for by the PCA but all other expenses had to be agreed in advance. The agreement also stated that PCA would cover the cost of the Appellant’s Loch Lomond membership for 2014 to enable him to host PCA’s trip to the club.