Tax treatment for overseas athletes performing in the UK

The 2020 Tokyo Olympics have now drawn to a close and although the stadiums in Japan were empty here in the UK we were treated to Andy Murray’s return to Wimbledon Lewis Hamilton’s triumph at the British Grand Prix England’s near-miss at Wembley and The Open Championship – all significantly enhanced by the return of spectators.

In this article we will be looking at the tax implications for athletes and entertainers who perform in the UK as well as some of the implications for this year’s Olympians.

UK regime

As most readers will already be aware if a non-UK resident employee performs duties in the UK which are not considered ‘merely incidental to duties outside the UK’ a proportion of their earnings will be subject to UK income tax under ITEPA 2003 s 27. The UK has double tax treaties with most...