Cristiano Ronaldo at the ripe age of 38 earning £170 million, who could blame him? What has followed, however, is a revolution of sorts, with dozens of top flight footballers in the peak of their careers following suit to Saudi Arabia.
Few British footballers have historically looked beyond the Premier League and yet, in almost an instant, the allure of playing football in foreign leagues has gained real traction, with Saudi Arabia emerging as the number one overseas league this summer owing to its ever-increasing global prominence and substantial salaries on offer. Forever the ones to crash the party, here comes a tax lawyer to sound the alarm. Yes, I am going to say it…the magic words ‘tax-free’ may be more taxing that you initially think.
UK tax on world wide income
To understand why, let us think about how UK tax generally operates in the context of the world of football. Even though Saudi Arabia does not charge income tax, that doesn’t mean you are totally outside the income tax net. As a starting point, if you are UK resident then you will very likely be subject to UK income tax on your worldwide income. Becoming non-UK resident can, of course, exempt our favourite footballers from UK income tax, but you have to pay close attention to the rules, really adhere to them and keep records of how you are getting on.
Taxing player businesses outside football
This is not just about employment income. As football aficionados will know, footballers derive their income from several sources, not all of which are employment related ie footballer kicks ball for club and club pays footballer money. Footballers will often generate substantial income from image rights and commercial endorsements.
What if the footballer has a company into which such income is paid and the company is UK incorporated – yes, you guessed it – ongoing exposure to UK tax. Going to Saudi Arabia, even as a non-UK tax resident is not going to eliminate all UK taxes, necessarily. Again, what if a player receives a signing bonus.
This will again come down to timing and the player will almost certainly be taxed on the basis of their UK residence at the time of receipt. So the question is how to address these structures to ensure they work tax efficiently when transfers dealings can happen, practically, overnight!
These rules can be tricky, particularly where players return after a complete season but half way through a tax year. Navigating the web of tax rules, as with any internationally mobile high-net worth individual, is essential to avoid any unwelcome surprises from the taxman back home. By keeping advised and well informed, players can rest easy and focus on the game. Who knows how long the bonanza will last, but where there is movement, there will always be tax implications!