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HMRC's Investigation Into Premiership Rugby's Image Rights Payments

HMRC's Investigation Into Premiership Rugby's Image Rights Payments
Thursday, 25 March 2021 By Kelly Stricklin Coutinho

Following its recent investigations into football players’ employment contracts[1], it is reported that HMRC is now investigating rugby players’ contracts[2] in relation to the tax treatment of payments for image rights, and the tax treatment of agents’ fees,

This article examines the issues and sets out some of the possible implications for the examination and treatment of image rights.  Specifically it looks at:

  • What is being investigated?
  • How will HMRC assess the image rights payments?
  • The potential connection between image rights payments and salary cap rules
  • Tips for clubs and players

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About the Author

Kelly Stricklin Coutinho

Kelly Stricklin Coutinho

Kelly’s sports law experience is primarily in Tax and in EU/Competition law.  She acted for Wasps in cases R (on the application of Sky Blue Sports & Ors) v Coventry City Council & Ors (in the Supreme Court, the High Court and the Court of Appeal), in respect of alleged state aid. She has also acted in relation to other major sporting venues in respect of allegations of prohibited state aid and breaches of procurement law. Kelly has acted for HNW Individuals, including sports people, in respect of a range of matters, including the tax treatment of damages, image rights and agents fees, as well as commercial matters. She has acted on matters concerning the use of personal service companies and their tax treatment under IR35. She has many years’ experience in tax enquiries and litigation, and has represented sports clubs in VAT litigation and corporate tax disputes.

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