Sports image rights in the UK – countering tax evasion in the football industry

摘要

The debate over more effective tax regulation for top-earning athletes has recently intensified, following media reports about tax evasion in the football industry and the potential abuse of image rights arrangements to reduce tax liabilities. According to the 2016/2017 report by the UK Public Accounts Committee, 43 players, including Manchester United’s Wayne Rooney, 12 clubs and eight agents are currently the subject of open tax inquiries related to image rights agreements. In separate investigations, Cristiano Ronaldo and Jose Mourinho, have been targeted by Spanish and British tax authorities for allegedly moving more than £100 million in a tax avoidance scheme on the British Islands. This article provides an update on the status of recent efforts to reform the taxation of foreign domiciled persons and offshore trusts as at January 2017. The new rules may have implications on tax and image right structures commonly used by foreign wealthy footballers in or moving to the UK. While the proposals are a step in the right direction, it is noted that existing and forthcoming tax rules must be enforced more effectively to reduce tax evasion in the sports and entertainment industry to a bearable minimum.