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The way that personal tax applies to professional sports people is incredibly nuanced and there is currently no book that brings together all of the idiosyncrasies that apply specifically to sports people.
Agents, sports lawyers and sports professionals themselves are acutely aware of the implications of entering into improper tax schemes or even just failing to be compliant. There is a tangible shift in how professionals who support athletes approach their taxes. The industry is more alive now to improper tax investments and the devastating impact that this can and does have on their clients.
With this book, professionals will be able to dip into the sections they require and use the content to support their work and ensure they are providing holistic advice to their clients. The book will include real life overviews, case studies and flow charts and tables to make the information as digestible as possible. It is broken down into sections, focusing on all major sports.
List of contents
1. General Principals in Personal Tax
1.1 The importance of getting this right
1.2 Common Tax Traps
1.3 Jurisdictions of UK tax
1.4 Residence and non residence
1.5 HMRC powers
1.6 Treatment of non residents in the UK
1.7 General tax exemptions for athletes
2 Football & Rugby
2.1 Pre Professional
2.1.2 Qualifying expenditure
2.1.3 Scholars & the salary jump
2.1.4 First �0k
2.2 Professional
2.2.1 International loans
Dutch & Belgian Football Loan Case
2.2.2 Domestic loans
2.2.3 Pensions cap
2.2.4 Agents' fees
2.2.5 Image rights companies
Hull City AFC (Tigers) Ltd v Revenue and Customs Commissioners [2019] UKFTT 227 (TC))
Sports Club plc v Inspector of Taxes [2000] STC (SCD) 443
2.11 Tax efficient investments (EIS, SEIS)
3 Golf & Tennis & Boxing
3.1 Pre professional
3.1.1 Setting up a trade
3.1.2 When to notify HMRC
3.2 Professional
3.2.1 Tax on tournament winnings
3.2.2 Qualifying expenditure
3.2.3 When/If to set up a company
3.2.4 Image rights companies
3.2.5 Tournaments overseas (for UK residents)
3.2.6 Tournaments in the UK (for non UK residents)
4 E-sports
4.1 Pre professional
4.1.1 Setting up a trade
4.1.2. Under 16 earnings
4.2 Professional
4.2.1 Twitch, Patreon and Paypal donations
4.2.2 Tournament winnings
4.2.3 Qualifying expenditure
5 Athletes
5.1 Pre professional
5.1.1 Athletes Performance Award
5.1.2 Setting up a trade
5.2 Professional
5.2.1 Citizenship & residency
5.2.2 Major events (Commonwealth Games, Olympics)
6 Post pro career
6.1 Closing down or continuing IRCs
6.2 Second career
7 Pundits
7.1 General Principals
7.2 Tax position
7.3 HMRC enquiries
7.4 Cases
Basic Broadcasting Ltd v HMRC [2022] UKFTT 48 (TC)
McCann Media Ltd v HMRC [2022] ULFTT 104 (TC)
8 Supporting Materials
8.1 Residency & Domicile - flowchart
8.3 First year over �0k - Checklist
8.4 First Commercial deal - Checklist
8.5 Image Rights Company - Flow chart
8.6 Image Rights Company - Checklist
8.7 Responding to HMRC enquiry - Sample Letter
About the author
Sofia Thomas is a fellow of the Chartered Institute of Taxation and founder of Thomas Consulting, a tax practice which focuses on partnering with family solicitors to provide tax advice to their clients on family breakdown.
