HMRC to give yellow card to footballers' image rights

08 March 2017

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Chris Sanger, head of tax policy, EY, comments on taxation of image rights

The Chancellor announced that HMRC will publish guidelines for employers who make payments of image rights to their employers under separate contracts. The taxation of image rights, and particularly the image rights of footballers, were a focus of a Public Accounts Committee hearing in December 2016, with a perception that non-domicile footballers playing for UK clubs were able to receive payments for image rights without paying any UK tax. 

The taxation of such rights is currently based on tax case law, so it is hard to see how the tax treatment can be substantially changed without legislation. But for footballers currently benefitting from the favourable treatment of image rights it looks like they may be in the last few minutes of the match and any added time is unlikely.