(Bloomberg) In the 2010 movie Robin Hood, a leather-clad Russell Crowe clashes with King John, whose harsh taxes displeased England’s medieval knights and barons. Now the makers of the film have accused Britain’s modern tax collectors of abusing their power by unfairly targeting its stars, including Crowe.
NBCUniversal unit Merry Men Films Ltd. has asked a U.K. court to review a decision by Her Majesty’s Revenue & Customs to charge it for employers’ national insurance contributions on the money paid to some of the film’s stars, according to court documents filed January and made available Thursday.
Crowe and the other performers aren’t named as participants in the case in the available legal documents, and there are no allegations of wrongdoing.
HMRC denied abusing its powers in its documents from the case. After a 2012 legal ruling that actors’ wages were covered by national insurance, HMRC said it was entitled to pursue taxes linked to Crowe and another actor, Max von Sydow, even though the film pre-dated that decision. The agency argued it had given no assurances at the time that they would be exempt.
David Hodgson, an NBCUniversal employee named in the papers, didn’t immediately respond to an e-mail seeking comment. HMRC spokesman Patrick O’Brien declined to comment.
Movie Taxes
The case is the latest tax dispute to erupt from the U.K.’s film industry. HMRC has cracked down on misuse of movie tax breaks, leading to lawsuits and criminal prosecutions. Meanwhile, the agency has been accused of causing confusion by changing the rules and re-opening historic tax returns that it once approved.
Documents filed by Merry Men and HMRC didn’t disclose the amount of money at stake. However, Russell Crowe was paid $20 million to appear in Robin Hood, according to the IMDB movie database. The rate paid by employers on national insurance contributions is 13.8 percent, meaning that NBCUniversal would owe about $2.7 million on his fee.
According to U.K. company registry filings, Merry Men Films is ultimately owned by NBCUniversal Media LLC, part of Comcast Corp.
Robin Hood was filmed in various locations around the U.K., including Pembrokeshire in Wales and Surrey in England, and cost about an estimated $200 million to make, according to IMDB. The movie earned about $320 million worldwide.
The case is: The Queen on the Application of Merry Men Films Ltd. v Commissioners for Her Majesty’s Revenue & Customs, Queen’s Bench Division, Administrative Court: CO/88/2016
