Tax Essentials for Sports Professionals

1. General Principals in Personal Tax 1.1 The importance of getting this right 1.2 Common Tax Traps 1.3 Jurisdictions of UK tax 1.4 Residence and non residence 1.5 HMRC powers 1.6 Treatment of non residents in the UK 1.7 General tax exemptions for athletes 2 Football & Rugby 2.1 Pre Professional 2.1.2 Qualifying expenditure 2.1.3 Scholars & the salary jump 2.1.4 First GBP100k 2.2 Professional 2.2.1 International loans Dutch & Belgian Football Loan Case 2.2.2 Domestic loans 2.2.3 Pensions cap 2.2.4 Agents' fees 2.2.5 Image rights companies Hull City AFC (Tigers) Ltd v Revenue and Customs Commissioners [2019] UKFTT 227 (TC)) Sports Club plc v Inspector of Taxes [2000] STC (SCD) 443 2.11 Tax efficient investments (EIS, SEIS) 3 Golf & Tennis & Boxing 3.1 Pre professional 3.1.1 Setting up a trade 3.1.2 When to notify HMRC 3.2 Professional 3.2.1 Tax on tournament winnings 3.2.2 Qualifying expenditure 3.2.3 When/If to set up a company 3.2.4 Image rights companies 3.2.5 Tournaments overseas (for UK residents) 3.2.6 Tournaments in the UK (for non UK residents) 4 E-sports 4.1 Pre professional 4.1.1 Setting up a trade 4.1.2. Under 16 earnings 4.2 Professional 4.2.1 Twitch, Patreon and Paypal donations 4.2.2 Tournament winnings 4.2.3 Qualifying expenditure 5 Athletes 5.1 Pre professional 5.1.1 Athletes Performance Award 5.1.2 Setting up a trade 5.2 Professional 5.2.1 Citizenship & residency 5.2.2 Major events (Commonwealth Games, Olympics) 6 Post pro career 6.1 Closing down or continuing IRCs 6.2 Second career 7 Pundits 7.1 General Principals 7.2 Tax position 7.3 HMRC enquiries 7.4 Cases Basic Broadcasting Ltd v HMRC [2022] UKFTT 48 (TC) McCann Media Ltd v HMRC [2022] ULFTT 104 (TC) 8 Supporting Materials 8.1 Residency & Domicile - flowchart 8.3 First year over GBP100k - Checklist 8.4 First Commercial deal - Checklist 8.5 Image Rights Company - Flow chart 8.6 Image Rights Company - Checklist 8.7 Responding to HMRC enquiry - Sample Letter