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FA 2010 comment: Champions League final 2011

It is safe to assume that the football supporters who file into London's Wembley Stadium for the FA Cup Final on 15 May will not be carrying copies of the Finance Act. However they may have cause to be grateful for a tax exemption contained in the final few pages of the Act as it has attracted the 2011 UEFA Champions League Final to Wembley.

The exemption is for non-resident employees or contactors of an 'overseas team' which competes in that final and is understood to have been a critical factor in Wembley's successful bid to host that event. Wembley had lost out to Madrid in the bid to host the 2010 final apparently in part because of the UK's tax rules.

The tax rules in question impose UK income tax on income derived by non-resident sportspersons (and entertainers) from performing in the UK. In...

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