QE Tax Flash: Tax on football match fees? No goal for HMRC

Tax on football match fees depends on a simple question: Is a referee an employee? If NOT an employee, neither income tax nor national insurance contributions need to be deducted from the match fees paid. 

While the question is simple, the applicable test is complex and multi-factorial. The tax court originally decided in a 2018 judgment that Professional Game Match Officials Limited had no obligation to deduct tax as there was insufficient mutuality of obligation and insufficient control for individual match appointments to amount to contracts of employment. Following multiple appeals, the Supreme Court then remitted the case to the tax court, which revisited the test to be applied in a new decision in Professional Game Match Officials Limited [2026] UKFTT 00654 (TC). The tax court saw “skilled professionals participating voluntarily in a regulated framework, undertaking discrete engagements for remuneration while retaining substantial autonomy and independence” and held it to be a serious hobby, but not one that paid the bills, so that the relationship with the referees could not be characterised as one of employment. No tax to be deducted before payment. No goal for HMRC.

Liesl Fichardt: “The decision is the latest chapter in a saga that is reshaping the law on employment status and its tax consequences.”

Emily Au: “After almost ten years of disputes, the taxpayers will be glad that the end is in sight, but decisions over employment status are highly fact-specific, and leave businesses and self-employed contractors with great uncertainty.”

Julius Berling; “The distinction the FTT draws between regulatory oversight and direct managerial control matters well beyond football. It may prove a key line of defence for organisations in many sectors resisting an employment status finding.”