As a result of the commercialisation of the international world of sport, nowadays many sportsmen have taken the opportunity to explore their possibilities with foreign sports clubs. Many types of sports are experiencing the possibilities of the borderless markets from which they can attract new players.

Football is the sport leading the way in international transfers. Especially from Europe, there is a high demand for soccer players from all regions in the world. Often, they get offered a contract to work outside their country of origin for a European soccer-club. The highest demand for these players comes from Italy, Spain and France, followed by the United Kingdom of Great Britain, Germany and The Netherlands.

Sports persons and sports club managers are bound to having to deal with tax matters. Moreover, many sportsmen are also active outside of their own country increasing the complexity of financial implications. In this complex financial environment, many questions arise. How can they benefit from a more favourable structure for your foreign activities? How can they receive expenses and bonuses in a tax-friendly manner? In addition, the end of a sporting career raises questions too. How to prepare for a life after sports? And how to wisely structure the capital raised?

Amicorp is made up out of professionals who are committed to discretion and excellence. We can advise sports clubs (particularly football clubs), service and management companies, as well as event entrepreneurs and other organizations involved in the world of sport. We also advise many players and sports people on a personal level about tax optimization and estate planning.

Normally, the main aspects of players' contracts connected to a move to Europe are:

a) Transfer Agreement between present club and new club
b) Fixed Salary Contract between new club and player
c) Image Rights Contract between new club and player (or third party)

The rights of a sports person in respect of the reproduction and use of their image are well known. But how is the income from this and other revenues (e.g. product endorsements) treated in terms of tax and the law? Based on years of practical experience, Amicorp is able to explain all the relevant tax implications related to a client's personal situation.

For example: Denmark provides excellent tax planning opportunities in respect to flowing income from (non-Danish) image rights. Danish treaties and national law grant an exemption from withholding tax for image rights received by and paid from a Danish company. Image rights in Denmark are considered "artistic" intangibles and, under Danish national law, are provided with an universal tax exemption from withholding taxation.

It is possible to use two corporate structures to flow through foreign source image rights without adverse tax implications. Legal opinions from reputable parties have been obtained in order to confirm these Danish tax positions and advanced rulings available. However, as tax regulations are subject to change, we recommend local tax advice to be obtained ensuring no foreign tax implications are incurred.