Sports stars including footballers, athletes, rugby and tennis players are frequently paid for use of their image rights.

In December 2016, HMRC chief executive Jon Thompson told the Public Accounts Committee the government should review the ‘rather convoluted’ way in which elite sports stars pay tax on their image rights.

‘The vast majority of these players incorporate themselves, and therefore are paid gross for their image rights from the rental of the asset,’ he told the committee at the time. ‘Since a significant number are non doms, that money is then paid to a company which is outside the UK. A player from Italy, for instance, may already have a company set up when he comes over to a UK team for three years, so payments continue to that overseas company. That is the most significant risk.’

In the Budget document, the government said: ‘The government is aware that some employers pay image rights in respect of employees under separate contractual arrangements to employment income. HMRC will publish guidelines for employers who make payments of image rights to their employees to improve the clarity of the existing rules.’

The Budget 2017 document can be read here.