In Accountancy Daily on 1st July, Jon Elphick and Sian Armitage examine lessons from the recent ruling in the AFC Hull “Tigers” v HMRC First Tier Tribunal.
Read the article here:- https://www.accountancydaily.co/football-players-image-rights-taxable-earnings
The tribunal ruled that Hull’s payments for the image rights of one of its high profile footballers, Geovanni Gomez, constituted a golden hand shake which should have been subject to payroll taxes rather than the lower tax rates of an image rights arrangement.
However, this case is invaluable as a road map to how to structure image rights arrangements correctly. For example, Jon and Sian explain how a club need to be able to demonstrate that they have the capacity to monetise a player’s image by having enough experience, resources and ability. That is, they need to show substance to the arrangement, not just the correct legal form.

Jon Elphick, Tax Director

Sian Armitage, Senior Tax Manager