Apportioning image-rights and worldwide income for athletes who perform partly abroad

For an athlete who performs in several countries, it is not only appearance fees and prize money that get carved up across jurisdictions. Income from exploiting their image, endorsements, sponsorship tie-ins and licensing, is increasingly apportioned the same way: by reference to where, and how often, the athlete actually performed. A name worth money in many markets can generate a tax footprint in each of them.

This guide explains how authorities commonly apportion worldwide and image-rights income, why routing that income through a separate company draws growing scrutiny, and a forthcoming change worth watching. It is general information, not tax-structuring or legal advice, and this is a fast-moving, contested area, so treat every figure as illustrative and confirm the current position with a qualified adviser before acting.

How worldwide income is apportioned

The common principle is that an athlete's global income is sourced, in part, to the places where they performed. Authorities frequently apportion it by reference to days or appearances spent competing in a given country, so a portion of the athlete's worldwide earnings becomes taxable there even if it was paid elsewhere. The mechanics echo the duty-day approach used for salary, but the reach is wider.

Crucially, this can extend beyond match fees to income from exploiting image rights. Where an endorsement or sponsorship payment is tied to the athlete's profile as a competitor, authorities in some countries treat a share of it as connected to the performances in their territory and apportion accordingly. The exact basis, days, appearances, or a blend, varies, so confirm how a particular country measures the link before assuming how much of the image income falls into its net.

Image-rights structures under scrutiny

A long-standing approach is to hold image rights in a separate vehicle, commonly described as an image-rights company, which licenses the rights and receives the related income. The idea is to distinguish payment for performing, which is employment income, from payment for exploiting a distinct, valuable asset.

That separation is increasingly scrutinised. Authorities have grown sceptical of arrangements where the image-rights payment looks disproportionate to the genuine commercial value of the rights, or where it is hard to separate from reward for simply turning up and playing. The direction of travel in several places is to look through structures that do not reflect real substance and to recharacterise inflated image-rights payments as employment income. None of this means a genuine arrangement is improper, but it does mean the commercial rationale and the numbers behind it need to stand up on their own.

A forthcoming change to watch

Treat this section as a flag, not a settled rule. Commentary points to at least one jurisdiction moving to tax certain employment-related image-rights payments as employment income rather than as a separate licensing receipt, with a change discussed as taking effect around April 2027. Some commentary also quotes effective rates and additional employer social-security costs that could attach once such payments sit within the employment net.

Those figures are commentary, not confirmed policy, and the detail, timing and scope could all shift before anything takes effect. The practical point is that the favourable treatment some image-rights structures have relied on may narrow, so it is worth building flexibility into how income is received and recorded rather than assuming today's treatment will persist. Check the current position, and any enacted detail, with a qualified adviser before you plan around it.

Keeping records and flows clean

Whatever the eventual treatment, the defensible position rests on clean separation and clean records. If performance income and image-rights income are genuinely distinct, the money should look distinct: separate flows, separate documentation, and a clear record of which appearances and markets each receipt relates to. Apportionment claims and foreign-tax credits across countries all depend on evidence you can produce later.

Where income arrives in several currencies, mixing it into one balance makes the later sourcing analysis harder, not easier. Holding each currency as it is received, and keeping image-rights receipts separate from performance pay, makes it far simpler to show an authority how a figure was built up, and to set aside what may be owed in each place without unpicking a single commingled pot.

How Altery fits

Altery does not give tax-structuring advice, decide how your income should be apportioned or file anything for you, and it is not a bank. Its role here is indirect: it helps you keep distinct income streams genuinely separate, hold them in the right currencies and keep records clean for whatever apportionment analysis follows.

Multi-entity management lets you keep separate vehicles, for example an operating entity and an image-rights entity, cleanly apart, each with its own balances rather than money flowing through one mixed account. You can ring-fence amounts you expect to owe in dedicated pots, hold income across USD, EUR and GBP with multi-currency business accounts, and convert on your own timeline rather than at the moment funds arrive. Real-time balances and clean records make the per-country sourcing far easier to evidence. This is information only, not tax-structuring or legal advice; confirm how image-rights and worldwide income are apportioned, and any forthcoming change, with a qualified adviser.

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