Bloomsbury Professional Tax Insight: Tax Essentials for Sports Professionals

Sofia Thomas is a Chartered Tax Advisor (Fellow) and CEO of Juno Sports Tax. She is an award-winning tax expert and a lecturer in tax. Sofia is regularly instructed as an expert for contentious tax disputes and has extensive experience in the sports industry, her clients include premier league footballers, title winning boxers and Olympians. Sofia is regular lecturer in tax for the CIOT, MBL and STEP. Nick De Marco KC of Blackstone Chambers is ranked as one of the leading sports law barristers and the foremost practitioner in football disputes. As well as acting for international and national federations, premier league and international football clubs, players, athletes and their unions, Nick sits as an arbitrator across a number of sports: he is a member of the IAAF Disciplinary Commission, Sports Resolutions’ independent Panel of Arbitrators and Mediators and the specialist sports list of arbitrators at the Asian International Arbitration Centre. Legal 500 (2022) said Nick: “has the best working knowledge of the football regulatory landscape of the barristers at the Bar”. Nick is a member of the Editorial Board of Law In Sport and of ‘Football Legal’ and he writes and lectures on sports law issues. He is co-author of ‘Challenging Sports Governing Bodies’ (Bloomsbury, 2016) the author and General Editor of the first edition of ‘Football and the Law’ (Bloomsbury, 2018) and he hosts ‘The Sports Law Podcast’ (in association with Blackstone Chambers). He is a director of the British Association for Sport and the Law (BASL).

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 £100k
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 £100k – 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