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Some 90 per cent of foreign players from leading footballing nations have registered their image rights offshore to avoid paying tax
This is in contrast to a few years ago when just a handful of foreign players took advantage of a tax loop open only to non-British footballers. Other sports people, such as cricketers, racing car drivers and tennis players, have also begun to register their image rights offshore to avoid paying 22 per cent withholding tax and income tax to the Inland Revenue. The IR frowns on this but can do nothing so long as it is carried out legitimately. Bernard Mcilroy, a corporate tax solicitor at Hammond Suddards Edge, which acts for several footballer celebrities playing for UK clubs, said the income from image rights has exploded in recent years. He points to TV rights. "The rights for the 1998 World Cup were sold for $97m (£63m), while the same rights to the 2002 World Cup were sold for $789m (£511m)," he said. An estimated £30m a year is paid to some 250 foreigners plying their trade in the Premiership - income that is exempt from taxation. The structures are complex. A player places exclusive image rights in an offshore trust which, in turn, assigns a licence to an offshore image company in exchange for shares in it. The offshore company then grants a sub-licence to a Dutch licensing company, which becomes the beneficiary of any royalties. Players tend to use the Netherlands because it has signed a double taxation treaty with the UK. Exemption from payment of the withholding tax does not apply to countries which have not signed this treaty.