The sports presenter's dispute with HMRC centred on whether he was a freelancer or an employee.
Throughout proceedings, the presenter, 62, insisted all taxes were paid on the income via a partnership set up in 2012 with his ex-wife Danielle Bux.
Earlier tribunal documents said Mr Lineker was disputing the bill and it had been agreed he paid the income tax in full. Following the ruling an HMRC spokesperson said: "The tribunal has confirmed the off-payroll rules apply to partnerships, as we have always said.
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