Payments by a Premier League football club to an offshore company for a Brazilian footballer under an image rights agreement were in substance and reality a reward for the player’s services as a footballer, and therefore formed part of his earnings for income tax and National Insurance contributions purposes.

Summary

Payments by a Premier League football club to a Brazilian football player’s offshore company under an image rights agreement were in substance and reality a reward for the player’s services as a footballer, and therefore formed part of his earnings for income tax and National Insurance contributions (NICs) purposes.

Background

The appellant company ran a football club, which was promoted to the Premier League for the 2008/09 season. On 7 July 2008, the appellant