Kevin Offer (Hardwick and Morris) examines the tribunal decision in Hull City AFC (Tigers) Ltd v HMRC that provides the first judicial guidance since the Sports Club case on how to approach the question of whether a payment for image rights constitutes earnings.
While the UK’s new digital services tax hogged the limelight in the recent Budget, much less attention was paid to the fact that the proposed extension of withholding tax on royalties paid to tax havens (announced at the previous Budget) was...
