Taxation of Entertainers and Sportspersons Performing Abroad

Taxation of Entertainers and Sportspersons Performing Abroad
This book provides a unique and detailed insight into the taxation of entertainers and sportspersons in an international context.

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.

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This book is part of the EC and International Tax Law Series

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Taxation of Entertainers and Sportspersons Performing Abroad
https://doi.org/10.59403/1tc71tc
Chapter 1: The Canadian/US Experience
https://doi.org/10.59403/1tc71tc001
Chapter 2: The EU Experience
https://doi.org/10.59403/1tc71tc002
Chapter 3: The Influence of EU Law on the Design of Domestic Tax Law for Entertainers and Sportspersons
https://doi.org/10.59403/1tc71tc003
Chapter 4: Historical Development of Article 17 OECD Model: From the League of Nations to the 2010 OECD Model
https://doi.org/10.59403/1tc71tc004
Chapter 5: The 2014 Changes to Article 17 of the OECD Model Tax Convention
https://doi.org/10.59403/1tc71tc005
Chapter 6: Tax Treaty Issues Related to Qualification, Allocation and Apportionment of Income Derived by Entertainers and Sportspersons
https://doi.org/10.59403/1tc71tc006
Chapter 7: Image Rights, Sponsoring and Advertising Income
https://doi.org/10.59403/1tc71tc007
Chapter 8: The Application of Article 17(2) of the OECD Model Convention
https://doi.org/10.59403/1tc71tc008
Chapter 9: Elimination of Double Taxation Relief: Credit vs Exemption
https://doi.org/10.59403/1tc71tc009
Chapter 10: International Sports Events and Tournaments
https://doi.org/10.59403/1tc71tc010
Chapter 11: Football Players – Employees rather than Sportspersons: An Exception to Article 17 OECD Model
https://doi.org/10.59403/1tc71tc011
Chapter 12: Argentina
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Chapter 13: Australia
https://doi.org/10.59403/1tc71tc013
Chapter 14: Austria
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Chapter 15: Belgium
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Chapter 16: Canada
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Chapter 17: France
https://doi.org/10.59403/1tc71tc017
Chapter 18: Germany
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Chapter 19: Italy
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Chapter 20: Netherlands
https://doi.org/10.59403/1tc71tc020
Chapter 21: Poland
https://doi.org/10.59403/1tc71tc021
Chapter 22: Portugal
https://doi.org/10.59403/1tc71tc022
Chapter 23: Spain
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Chapter 24: Switzerland
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Chapter 25: United Kingdom
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Chapter 26: United States
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Chapter 27: Conclusions
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Contributors
https://doi.org/10.59403/1tc71tc028
Other titles in this series
https://doi.org/10.59403/1tc71tc029