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Taxing celebrities’ income from the exploitation of image rights
KEY POINTS
- Earnings can arise from the potential to exploit a taxpayer’s image and name.
- HMRC recently issued new guidance and views in the Capital Gains Manual.
- UK law does not acknowledge image rights but these will comprise a bundle of tangible and intangible assets.
- The valuation of image rights will be important but is subject to differing views.
- Image rights can have additional importance for foreign personalities.
Practitioners in the sports and entertainment worlds will be familiar with the concept of image rights and their exploitation.
Although relevant to sports and media personalities generally it is particularly pertinent in advising UK resident Premier League footballers whether UK domiciled or not given the competition’s worldwide profile and the diverse nationalities of the players within it.
The...
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