According to UK newspaper the Financial Times, HMRC believes image rights paid to footballers are a form of remuneration and should be taxed as income. However, most of those payments are made to “image-rights” companies set up by players, normally based offshore and out of reach of British tax legislation.
Revenue & Customs suspects the practice has been put in place to attract overseas players that otherwise would have been put off by UK taxation levels.
The Premier League is understood to be examining the idea of a banding system whereby big earners would be allowed to assign a higher share of their earnings to image-rights payments.


