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09 September 2014 / Julian Hedley
Issue: 4468 / Categories: Comment & Analysis , sport , Income Tax , International

The efficacy of tax exemptions for UK sporting events featuring non-resident athletes


  • The provision to give tax exemptions for sporting events is contained in FA 2014 s 48.
  • The new legislation fails to address the problem of how to tax overseas sportsmen’s endorsement income.
  • Between 1987 and 1999 a service element of endorsement income was taxable according to the number of days spent in the UK.
  • HMRC changed this practice so that all the income including image rights was subject to apportionment.
  • Given the small amount of tax at stake why not exclude all endorsement income of non-UK resident athletes?

The power to provide tax exemptions for major sporting events was introduced in FA 2014 s 48 and indicates that there is still high-level support for attracting major sporting events to the UK.

Importantly it...

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