Those 804 contracts are with "on-air talent" who are paid more than £50,000 for their work.
Having reviewed those contracts, the BBC said that 131 people will be moved onto staff contracts when their current freelance deals expire.
The BBC declined to discuss the individuals affected, but the Deloitte review makes clear they include some of the most famous and highly-paid presenters on television and radio.
There is no suggestion that any of the presenters has broken any tax rules in their dealings with the BBC.
Anthony Fry, a member of the BBC Trust, said that the stars affected will have no choice but to accept staff contracts. He said: "Will we allow exceptions? We will not. There will be no exceptions because someone is a big talent."
Zarin Patel, the BBC's finance director, insisted that the Deloitte report showed "no evidence" that the BBC was party to tax avoidance.
However, she admitted that stars using personal service companies could reduce their tax bill by writing off up to 5 per cent of their income as "management expenses". The use of such arrangements "give the public the perception that individuals can avoid tax," she said.
Jeremy Paxman, the Newsnight presenter, claimed earlier this year that he had been told by the BBC that he had to set up a company to receive his earnings from the corporation.
Ms Patel insisted the BBC had done nothing wrong by pushing some workers to register themselves as companies in ealier years.
People registered as personal service companies can also pay corporation tax of 21 per cent on earnings. Individuals paid under the PAYE tax system incur income tax of up to 50 per cent.
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