https://www.theguardian.com/football...mrc-in-2019-20


Tax authorities increasingly concerned by tax loophole
Players pay 19% tax on image rights compared with 45% on wages
Paul MacInnes

HMRC does not believe some footballers are worth the amount they are being paid in images rights and suspect it is being used as a way to avoid 45% tax on wages. Photograph: Kirsty O’Connor/PA
The number of footballers investigated by HMRC rose dramatically in the tax year 2019-20, going up from 87 to 246 individuals, according to research by the accountancy firm UHY Hacker Young.

The figures show footballers and their image rights are coming under increasing scrutiny as the UK tax authorities look to clamp down on loopholes in the way players are paid.

The number of investigations into the tax affairs of football agents also increased substantially, more than doubling from 23 in 2018-19 to 55 in 2019-20.


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Hacker Young argues that this increase tallies with greater interest in the image rights regularly negotiated by players as an extension to their salary.

Image rights allow a club to use the name and the likeness of a player (as well as the actual individual when appropriate) to market and sell the club’s wares and those of their sponsors.

While a player’s wage, in the Premier League and Championship, will be levied with a 45% income tax charge, image rights are taxed at the 19% corporation tax rate, making it a far more lucrative mode of payment for the player.

While some players would be able to command enormous fees for their image rights and may have a more valuable brand than the club they play for, negotiating image rights is an increasingly standard practice among players with less name recognition too.


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Elliot Buss, a partner at UHY Hacker Young says: “HMRC believes that lots of lesser-known footballers are effectively avoiding tax by getting paid huge sums for image rights that HMRC views as overpriced.

“The image rights of the likes of Paul Pogba and Mohamed Salah are undoubtedly worth millions of pounds a year. However, if you are second-choice left back in the Championship getting paid a great deal in image-rights payments, then this is likely to trigger an investigation by the taxman. You may have to make a robust argument to HMRC to show how the value of the image rights has been arrived at.”

The kind of calculations that would be required to work out the value of a player’s image would include the amount of money they could charge for making a public appearance or for endorsing a product as well as the more traditional totting up around the sale of replica kits.