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A hurdle too far?
Key points
- For athletes sportspeople and entertainers where a payment is made which is connected to a UK activity a proportion of the income that relates to the UK is taxable here. The country where the performance takes place often has the primary taxing rights.
- Under the OECD model tax convention article 17 ‘artistes and sportsmen’ they do not need to spend a specific amount of time in the UK or have a UK permanent establishment in order to create a potentially significant tax liability.
- The UK has a two-pronged approach to collecting tax from overseas athletes who perform in the UK. However the UK is one of a minority of countries that also seeks to tax a proportion of an athlete’s global endorsement income.
- HMRC suggests one of two methods to calculate the UK apportionment of endorsement income for non-resident athletes. However...
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