Following the UK’s Budget last month, HMRC also announced it will publish guidelines for employers who make payments for image rights to their employees, “to help employers understand how these payments should be taxed”.
Last month, HMRC brought a case to the UK’s Supreme Court against Scotland’s Rangers Football Club for aiding and abetting tax avoidance.
It involved the use of employee benefit trusts (EBTs) in Jersey that paid tax-free loans to players and staff between 2001 and 2009, which HM Revenue & Customs claims robbed the public purse of £46.2m in unpaid tax.
Spanish tax crackdown
This latest move may suggest that HMRC is following the lead of its Spanish counterpart, the Hacienda, which in recent years has taken a harder line on the taxation of image rights by football players at Spanish clubs.
Earlier this year, Arsenal striker Alexis Sanchez was told he faced a possible jail sentence after admitting to tax fraud in Spain of almost €1m (£880,240, $1.06m).
Prosecutors said the 28-year-old Chilean avoided paying tax by “simulating” the transfer of his image rights – worth €983,000 – to Numidia, an offshore shell company in Malta during his stint at Barcelona between 2012 and 2013.
Last July, Argentinean footballer Messi and his father were sentenced to 21 months in prison by a Spanish court for tax fraud over €4.1m squirrelled away in tax havens in Belize and Uruguay between 2007 and 2009. The pair avoided jail as under Spanish law, prison sentences of less than two years can be served under probation.
Another Barcelona player Neymar and his father are also facing a two-year prison sentence and a $10.6m fine on corruption charges related to alleged irregularities during his transfer from Brazilian club Santos to Barcelona in 2013. Both have denied any wrongdoing.
