How to structure image rights companies for international athletes working in the U.K.

Published 06 February 2017 By: Jon Elphick

Tax woodblock letters under coins on table

There appears to be an increasingly common misconception in the media that international athletes set up image rights companies as a “tax dodge[1] or part of a “secret deal[2] 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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Jon Elphick

Jon Elphick

Jon is an International Tax Advisor who specialises in providing proactive and practical advice to UK resident, international private clients.

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