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Sporting chance

An athletic look at the taxation of non-resident sportspeople’s endorsement income

KEY POINTS

  • Withholding tax imposed on non-resident sportspeople.
  • All endorsement income brought into play.
  • Apportionment between passive and active elements.
  • The US taxes a proportion of a sportsperson’s income.
  • UK open to claims under double taxation agreements.

The issue of the tax treatment of non-UK resident sportspeople re-surfaced recently as the 2013 Budget introduced specific exemptions for two events to be held in the UK the London Anniversary Games in July 2013 and the Commonwealth Games 2014 in a bid to ensure the world’s top athletes attend.

Tax exemptions to encourage major sporting events and sportspeople to the UK appear to be desirable. But the reality is that the UK tax system is out of line with the rest of the world and such exemptions are becoming...

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