The GTN Sports Tax Team provides UK and international tax advice to professional footballers and other sports persons in association with our global network of partner firms.
Our clients include sports professionals moving to or leaving the UK on short term or permanent contracts and those present on a temporary basis during exhibition tours and events. We provide assistance in a diverse range of sports and represent a number of Premier League and EFL football clubs, players and international scouts.
Services we provide include:
Preparation of tax returns
It is critical to have expertise in this area to determine taxation and optimisation of taxes on both a local and international level. We can assist clients with tax registrations, planning and tax return preparation in both the UK and multiple countries on a combined basis. Working with existing advisers or our GTN partner firms, we can review the tax reporting requirements of UK and overseas income, investments, image rights payments and application of double tax treaties to ensure the right tax filings and payments are being made to the correct jurisdiction.
Tax residency and planning
For permanent moves to or from the UK, we provide a full analysis of tax residence in early planning stages. In certain locations, an individual may move to a new country part way through the tax year (for example at the start of a new season), but may become tax resident and obliged to pay taxes for the entire year. It is therefore important to consider the best time to arrive in a certain country and the appropriate dates for the signature of new contracts and the signature of termination contracts. In many cases an individual may be resident in more than one country at the same time, which requires very careful analysis of the relevant double tax agreements in place.
Significant tax savings are available through the HMRC approved "non domicile" status to protect overseas investment income and assets from UK tax, as well as Overseas Workday Relief for exemption of earnings relating to matches/competitions outside of the UK. We have significant expertise advising clients in this area.
Payments for image rights
Tax authorities in many countries are now challenging the tax structure of image rights. The days of establishing offshore entities for assignment of those rights for non domiciled individuals has been challenged by HMRC in the UK and further limited by the Economic Substance rules. We can provide a review of such structures and confirm the taxation rules on a multi-jurisdictional basis, working alongside our UK and overseas partners and lawyers specialising in IP and trust services to implement optimal solutions in line with relevant government legislation.
Payments of agent fees
Payment of agent fees will require important analysis, as tax authorities in certain jurisdictions now deem these to be considered as salary and taxable in the hand of the player.
Our clients often have significant investments in other assets and can benefit from expatriate concessions, such as the UK "non domicile" status. Through the GTN network, we can provide legal and tax advice for such investments and deal with the accounting and tax returns of any investment companies. Our FCA regulated wealth management partners can advise on specific investments and pensions, whether UK based or offshore, in full co-operation with our global tax planning services.
It is also important to plan for retirement, since many professional sports persons may end their career at a younger age than most. We provide planning options, both within and outside of the UK and can assist with pension, estate planning and drafting of wills via our legal partners. This includes specialist pension structures that are fully portable when moving internationally during a career.
Many football clubs are unaware of the complex legal and compliance requirements when hiring international scouts. We have specialist experience in this area, and are assisting a number of Premier League football clubs with all global tax and social security requirements.
In most cases, tax is payable in the country of residence and not the UK and often tax registration of the UK club in the host location and payment of employer social security is needed. Typically, scouts are placed on UK contracts, however these often do not comply with legislation in the country in which the scout is resident. We can assist with the review and implementation of all global tax, social security, withholding and legal requirements to ensure that clubs remain fully compliant as their scouting networks expand internationally.
Exhibition tours and appearances
The UK tax authorities will seek to tax the proportion of both earnings and endorsement income relating to performances in the UK. Tax will be withheld by the club, agent or promoter and the individual will receive a form known as a FEU2 showing details of the tax deducted in the UK. Not all visiting professional sports persons are required to file tax returns if the tax withheld is sufficient to cover the final liability. If a return is required, then it is necessary to report a “fair proportion” of earnings from worldwide activities for time spent in the UK, including endorsement or sponsorship income. This is usually based on the proportion of “relevant performance and training days” that relate to the UK.
We can provide assistance with the review of withholding and preparation of tax returns where this is required.