Jonathan Peacock QC considers the policy behind the taxation of foreign-based sportspeople, and asks whether the ‘special deals’ for ‘special events’ should cause a wholesale rethink of how the UK positions itself in the worlds of sport and the arts.
In the beginning there was a problem and in the beginning there was a plausible solution. The problem was that foreign based (ie non-UK resident) sportsmen and women were earning monies from competing at tournaments in the UK and there was no obvious method by which they could be taxed on that income.
Indeed it was unclear whether the stars concerned were carrying on a trade or profession in the UK (did Centre Court at Wimbledon amount to a ‘permanent establishment’?) or whether non-tournament based income such...
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