Guide on Sportsperson Taxation in Certain Relevant Jurisdictions

The Guide is basically aimed at the advisers and representatives of sportspersons, as well as at sportspersons themselves. In a world where it is increasingly common for sportspersons to change team and country of residence, the decision on what offer to accept is no longer only down to questions of a sporting nature, as the tax treatment that the sportsperson is going to receive in the country to which he or she is moving may also tip the balance. From this perspective, knowledge of the tax treatment is a highly relevant factor when negotiating a contract, since the variation in tax rates applying to the same gross package on offer can make one country, and thus one team, a far more attractive prospect than another. The Guide presented by us offers a brief description of the tax issues that will affect a sportsperson who is relocating to certain jurisdictions. Although there are undoubtedly other jurisdictions that should be analyzed, we have picked as our starting point the most common countries of origin and destination for sportspersons. The Guide takes an essentially descriptive approach. Obviously, the aim is by no means to give an exhaustive account of the tax treatment of sportspersons in each country, but rather to describe the general personal taxation framework that they will be facing, so that, if it is felt necessary, such framework can then be explored in greater depth. As a source of reference for initial consultation, we believe that both representatives and advisers will find the Guide highly useful, although in the particular case of advisers, the Guide will also provide them with an preliminary overview of the issues to be borne in mind and analyzed by them. Issues such as the rules on inbound expatriates, the tax treatment of image rights, the exploitation of such rights through corporate vehicles, the tax treatment of nonresidents, and the concept of ‘residence’, are among the topics covered in this Guide.