Why this book?
Taxation of Entertainers and Sportspersons Performing Abroad, comprising the proceedings and working documents of an annual seminar held in Milan in November 2015, is a detailed and comprehensive study on the taxation of highly mobile individuals engaged in the artistic and sports sectors. It begins with a comparative analysis of the domestic tax regime of such individuals and then examines the influence of EU law on national law, with a particular emphasis on the jurisprudence of the Court of Justice of the European Union.
The book then moves to selected tax treaty issues. In particular, it analyses: (i) the history of article 17 of the OECD Model Tax Convention; (ii) recent developments concerning that article, particularly the 2014 amendments to the Commentary on Article 17 of the OECD Model Convention; (iii) tax treaty issues related to qualification, allocation and apportionment of income derived by entertainers and sportspersons; and (iv) the taxation of income from image rights, sponsorship and advertising.
Special attention is devoted to the application of article 17(2) of the OECD Model Convention, issues concerning the elimination of international double taxation and the taxation of international sport events and tournaments, such as the Olympic Games and the UEFA and FIFA Championships.
Individual country surveys provide an in-depth analysis of the domestic tax regimes and actual tax treaty application and practices by various states, including Argentina, Australia, Austria, Belgium, Canada, France, Germany, Italy, the Netherlands, Poland, Portugal, Spain, Switzerland, the United Kingdom and the United States.
This book presents a unique and detailed insight into the taxation of entertainers and sportspersons in an international context and is therefore an essential reference source for international tax students, practitioners and academics.