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Image rights and HMRC

10 June 2019 / Jon Elphick
Issue: 4699 / Categories: Comment & Analysis
Image management

Key points

  • A footballer signed an employment contract with a football club before a separate contract was drawn up to exploit his image rights.
  • The image rights contract was between a British Virgin Islands company and the club.
  • The amount paid for the image rights was a percentage of his employment income.
  • There was no evidence that the club exploited the image rights nor that the BVI company owned them.
  • HMRC issued directions to collect income tax and National Insurance contributions on the payments for image rights.
  • The tribunal determined that the image rights payments were to encourage the footballer to join the club.

Geovanni Deiberson Mauricio Gómez (known simply as ‘Geovanni’) is a retired Brazilian footballer. He enjoyed a distinguished playing career with clubs such as Barcelona Benfica and Manchester City and even won a cap for Brazil. However it is his time with Hull City Football Club that is of most interest to...

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