Moving the goal posts: higher tax on sports image rights

Major changes to tax on sports image rights will see national insurance charged on employment related income, raising urgent tax planning issues for football clubs and players, explain Martin Smith, partner and head of sports team and Gurdeep Dhanjal, senior manager at HW Fisher

Buried in the 2025 Budget's fine print lies a change that could fundamentally alter how the sports industry operates. While the government’s wider tax reform package aims to raise £2.3bn, one measure targeting image rights payments threatens to upend decades of established practice in professional sports.

The headline figures tell only part of the story. HM Treasury expects the measure to generate £40m annually, a small sum in fiscal terms but one that could have far-reaching consequences for football clubs, athletes, and their advisors.

From 6 April 2027, all image right payments linked to employment will be treated as taxable employment income, subject to income tax and national insurance contributions (NICs) from both employers and employees.

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