Strategic Tax Planning & Compliance in Sports
The cross-border nature of the sports industry creates highly complex tax scenarios. Professional athletes, coaches, agencies, and clubs are subject to intense scrutiny by national tax authorities. A lack of specialized tax planning can lead to severe financial and reputational consequences.
At UNO-ONE Legal, we provide sophisticated tax advice tailored to the unique realities of the sports sector. We help our clients navigate international tax treaties, structure their remuneration efficiently, and ensure full compliance across multiple jurisdictions.
Image Rights Structuring
The commercial exploitation of an athlete’s image is a critical source of revenue, but it is also a primary target for tax audits. We design secure and compliant structures for image rights management.
- Corporate Structuring: Advising on the creation and management of image rights companies (IRCs) in compliance with national legislation and international anti-abuse rules.
- Contractual Alignment: Ensuring that the allocation of income between employment contracts and image rights agreements reflects genuine commercial reality and meets tax authority guidelines (e.g., the 85/15 rule in Spain).
- Sponsorship Taxation: Analyzing the tax implications of global endorsement deals and the withholding tax obligations in different territories.
International Tax Mobility
When players transfer between countries or compete internationally, determining tax residency and avoiding double taxation is paramount.
- Tax Residency Planning: Advising athletes and coaches on the implications of relocating to a new country and managing the transition between tax systems.
- Special Tax Regimes: Assisting clients in applying for favorable expat tax regimes (e.g., the “Beckham Law” in Spain or similar schemes in Italy and the UK) to optimize their net income.
- Double Taxation Treaties: Structuring cross-border payments—such as transfer fees, agent commissions, and prize money—to mitigate withholding taxes and utilize foreign tax credits.
Tax Litigation & Agency Audits
Tax authorities increasingly target the sports sector, focusing on agent fees, sign-on bonuses, and image rights. We provide robust defense in tax disputes.
- Tax Audits: Representing athletes, clubs, and intermediaries during inspections by national tax agencies, managing information requests, and negotiating settlements.
- Intermediary Taxation: Defending clubs and agents in disputes regarding the VAT treatment of agency fees and the controversial “dual representation” tax implications.
- Litigation: Leading appellate proceedings before administrative tax courts and ordinary judicial instances to challenge unjustified tax assessments and penalties.
