Kevin Offer (Hardwick and Morris) examines the tribunal decision in Hull City AFC (Tigers) Ltd v HMRC that provides the first judicial guidance since the Sports Club case on how to approach the question of whether a payment for image rights constitutes earnings.
The case of Sports Club Plc v HM Inspector of Taxes [2000] STC (SCD) 443 has long been the only judicial view that payments under an agreement for the use of the image rights of a professional footballer can be separate to the playing activities for which the player is employed by a club. This decision led to an increase in the use of image rights structures partly driven by agents of overseas players and a general understanding that it was acceptable to pay up to 25% of basic salary in the form ...
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Kevin Offer (Hardwick and Morris) examines the tribunal decision in Hull City AFC (Tigers) Ltd v HMRC that provides the first judicial guidance since the Sports Club case on how to approach the question of whether a payment for image rights constitutes earnings.
The case of Sports Club Plc v HM Inspector of Taxes [2000] STC (SCD) 443 has long been the only judicial view that payments under an agreement for the use of the image rights of a professional footballer can be separate to the playing activities for which the player is employed by a club. This decision led to an increase in the use of image rights structures partly driven by agents of overseas players and a general understanding that it was acceptable to pay up to 25% of basic salary in the form ...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
