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Image rights payments are earnings

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For the first time in almost 20 years, in Hull City AFC (Tigers) Ltd v HMRC the First-tier Tribunal has considered the approach that should be taken when looking at payments made for the use of the image rights of a professional footballer. Hull City entered into an image rights agreement with an offshore company to which the player had assigned his image rights. The tribunal judge held that the payments were part of the player’s earnings from employment with the football club based on substance over form. The club should therefore have accounted for income tax and national insurance on the payments.

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