Taxation of Entertainers and Sportspersons

A detailed guide to the taxation of entertainers and sportspersons in three volumes and electronically. There is no recent publication on this. This publication is for the practitioner and others written by a practitioner who has been an academic. Its design follows his way of working beginning with the basic materials and analysing them for application to any particular case.

It is a starting point for the adviser in a hurry. It includes Key Points boxes to help as well as full contents for each Chapter. There are also many tables and checklists. There is often a further detailed analysis including on Article 17 OECD Model Treaty, HMRC’s published views on “Image Rights”, the 1987 Regulations and DTR. There is also a detailed Chapter on Avoidance. It includes many examples. Relevant statutory and related material are included in the text so everything is easily available.  Tax law requires an understanding of the legal analysis of the underlying matters. Accordingly, matters such as “Image Rights” or “Personality Rights”, the Economic Torts, Confidentiality and Passing Off are dealt with. There is also a detailed case study at the end intended to bring matters together.

The 30 October 2024 Budget made significant changes to some of the important matters discussed in the Book. Matters such as the changes to “Non-Dom” Taxation and the Remittance Basis as well as changing IHT and Overseas Workday Relief to a residence basis will have a profound effect on the practice of UK tax for many involved with ESPs particularly with ESPs performing on the Global Stage.

However, much of the Book is not so affected such as the discussion of Residence, the 1987 Regulations, “Image Rights”, the Anti-avoidance provisions (subject to exceptions), personal branding and the content of the long chapter on filing. These will remain of great importance.

The intention is to produce a second edition of the Book to reflect the changes in the Budget as enacted into law. Governments have been known to introduce amendments to Finance Bills at a late stage. Accordingly, the relevant legislation is necessary so as to be able to produce a new edition in the same style as the first. The intention is to produce the second edition as soon as is practical.

That said the first edition will remain relevant for many years to come. Tax enquiries and disputes generally and particularly in respect of ESPs arise by reference to earlier years. They can go on for many years and can arise some years after the year in question. The first edition will provide a useful source of information and guidance for such matters in future years.