How to structure image rights companies for international athletes working in the U.K.
There appears to be an increasingly common misconception in the media that international athletes set up image rights companies as a “tax dodge” or part of a “secret deal” in an illegitimate attempt to reduce their UK tax liabilities.
In the author’s experience, such comments bear little resemblance to the requirements for any image rights arrangements to be legitimately established, both from a professional perspective and in the eyes of the UK tax authority, HM Revenue and Customs (“HMRC”).
This article looks at how international athletes living in the UK can structure their image rights arrangements to ensure that they are within the law. Specifically, it examines:
- HMRC’s current view on image rights;
- A short refresher on image rights companies;
- Non-UK image rights companies, and how international athletes working in the UK can use them effectively (including a worked example); and
- Author’s comment
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- Tags: Companies Act 2006 | Corporate | European Union | Finance (No 2) Act 2015 | Finance Act 2016 | HM Revenue & Customs (HMRC) | Image Rights Companies | Income Tax Act 2007 | Intellectual Property | Tax | Treaty on the Functioning of the European Union (TFEU) | United Kingdom (UK)
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- Attracting top talent: Why the UK should reconsider the way it taxes non-resident athletes
- How athletes will be affected by the UK’s changes to “non-dom” tax rules