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Taxation of Entertainers and Sportspersons

Taxation of Entertainers and Sportspersons

Name: Taxation of Entertainers and Sportspersons
Brand: Spiramus Press Ltd
SKU: 9781910151099
Price: 3923.50 HKD
Availability: InStock
Author: Adrian Shipwright
ISBN: 9781910151099

By Adrian Shipwright

Spiramus Press Ltd November 2024

Specifications

ISBN-13: 9781910151099
Publisher: Spiramus Press Ltd
Publication: November 2024
Format: Paperback (3 volumes)
Jurisdiction: U.K. ? Countri(es) for reference only

Details

A detailed guide to the taxation of entertainers and sportspersons to be released in three volumes and electronically. There is no recent publication on this. This publication is for the practitioner and others written by a practitioner who has been an academic. Its design follows his way of working beginning with the basic materials and analysing them for application to any particular case.

It is a starting point for the adviser in a hurry. It includes Key Points boxes to help as well as full contents for each Chapter. There are also many tables and checklists. There is often a further detailed analysis including on Article 17 OECD Model Treaty, HMRC’s published views on “Image Rights”, the 1987 Regulations and DTR. There is also a detailed Chapter on Avoidance. It includes many examples. Relevant statutory and related material are included in the text so everything is easily available. Tax law requires an understanding of the legal analysis of the underlying matters. Accordingly, matters such as “Image Rights” or “Personality Rights”, the Economic Torts, Confidentiality and Passing Off are dealt with. There is also a detailed case study at the end intended to bring matters together.

Volume 1; Publisher’s Note; Foreword; Abbreviations and Glossary; Preface; 1.
Introduction: 1.1 Purpose and General Matters; 1.2 Structure of this Book; 1.3 What Is Meant By ESPs (Entertainers and Sportspersons) for the Purposes of the Book; 2.
The Relevant UK Taxes and Levies: 2.1 Introductory Matters; 2.2 UK Income Tax - an Overview; 2.3 UK Capital Gains Tax- an Overview; 2.4 UK Corporation Tax - an Overview; 2.5 IHT; 2.6 VAT; 2.7 NIC - National Insurance; 2.8 Annexe – Client Questions; Appendix 1: UK Income Tax (“IT”) – General; Appendix 2: UK Corporation Tax – General; Appendix 3: Transfer Pricing and the UK; Appendix 4: Diverted Profits Tax (“DPT”); Appendix 5: UK VAT - Outline Reminder on VAT; Appendix 6: Some Matters for Consideration for Any Jurisdiction.; 3.
UK Tax and Connecting Factors: 3.1 Introduction; 3.2 “Source”; 3.3 “Residence”; 3.4 Domicile; Appendix 1: Summary SRT; Appendix 2: Split Year Treatment; Appendix 3: Definitions and Clarifications; Appendix 4: Initial Checklist for Residence and Related Matters; Appendix 5: Initial Domicile Questionnaire; Appendix 6: Offshore Income and Gains and the Remittance Basis; Appendix 7: March 2024 Budget Remittance Etc. Changes and Later Announcements; 4.
Ways of Carrying on the Business for an Actor or Sportsperson: 4.1 Introduction; 4.2 UK Tax on Different Ways of Carrying on the Business; 4.3 Liability to United Kingdom Tax of Entertainers and Sportsmen; 4.4 Annexe; 4.5 Trade/Profession Or Employment?; 4.6 Clothing; 4.7 Medical Expenses; Appendix 1: Comparative General Table on Tax of Entities With UK Resident Owner; 5.
Points, Residuals and Post Cessation Receipts: 5.1 Introduction; 5.2 Profit and Earnings Recognition – Some General Comments; 5.3 Visiting Performers; 5.4 Post Cessation Receipts; 5.5 Deemed Cessation; 5.6 What About Companies?; 5.7 Transfers Etc.; 5.8 Tailpiece; 6.
Anti-Avoidance: 6.1 Introduction; 6.2 UK Approach to Avoidance; 6.3 The Settlement Provisions; 6.4 Capital Gains Tax – Some Avoidance Provisions; 6.5 Transactions in Securities; 6.6 Sale of Occupation Income; 6.7 Tax Havens; Appendix 1: Interpretation and Definitions Etc.; Appendix 2: Protected Trusts; 7.
Administration and Collection of Tax: 7.1 Introduction; 7.2 What Is HMRC?; 7.3 Judicial Review (“JR”); 7.4 Further Materials; 7.5 Legitimate Expectation; Volume 2; 8.
Foreign Self-Employed ESPs: 8.1 Introduction; 8.2 General; 8.3 ITA Provisions; 8.4 The 1987 Regulations; Appendix 1: Simplified Flowchart on Deductibility; Appendix 2: Some Definitions of Relevant Words and Phrases; Appendix 3: Schedule 11 Entertainers and Sportsmen; Appendix 4: HS 3032024; 9.
Royalties: 9.1 Introduction; 9.2 Royalties; 9.3 UK Direct Tax Charge on Royalty Income; 9.4 Withholding Tax and Royalties; 9.5 Excursus on Annual Payments; 9.6 UK Withholding Tax—Overview; 9.7 Withholding Tax on Payments Relating to Intellectual Property; Appendix 1: Some Useful HMRC Extracts; 10.
Endorsement, “Image Rights”, Appearances and the Like: 10.1 Introduction; 10.2 “Image Rights” and the Like; 10.3 Guernsey; 10.4 Image Rights in Practice; 10.5 Endorsement, Sponsorship Etc.; 10.6 Design and Promotion; 10.7 Personal Appearances; 10.8 NFTs; Appendix 1: Breach of Confidence; Appendix 2: The Economic Torts and Related Matters; Appendix 3: Guernsey Image Rights; 11.
Particular Activities for ESPs Including Personal Branding: 11.1 Introduction; 11.2 Personal Branding; 11.3 Establishing a Trademark Etc.; 11.4 Vehicle(S) for Personal Brand; 12.
Intermediaries Legislation (IR5 Etc.): 12.1 Introduction; 12.2 General Matters; 12.3 Relevant Criteria and Approach to Determining Employment Status; 12.4 Application of Provisions to Agency Workers Chapter 7; 12.5 Workers' Services Provided Through Intermediaries to Small Clients Chapter 8; 12.6 Managed Service Companies Chapter 9; 12.7 Chapter 10 “Workers' Services Provided Through Intermediaries to Public Authorities Or Medium Or Large Clients [Sections 61k–61x]”; 12.8 Conclusion; Appendix 1: Employment Status Manual; 13.
Double Taxation: 13.1 Introduction; 13.2 Sources of Information and HMRC’s Views; 13.3 What Is Double Taxation?; 13.4 Capital Gains Etc.; 13.5 Miscellaneous Matters; 14.
Double Tax Treaties: 14.1 General; 14.2 Interpretation of Tax Treaties; 14.3 Some Extracts From the OECD Model Treaty [2017]; 14.4 Jurisdiction to Tax; 14.5 Residence of Persons; 14.6 Domicile; 14.7 Activities/Sources; 14.8 Source Country Taxation; 14.9 Permanent Establishment (PE); 14.10 Mobile Investment Income Under Model Treaties: Dividends, Interest, Royalties; 14.11 Interest; 14.12 Royalties; 14.13 Capital Gains; 14.14 Income From Employment; 14.15 Lifetime Taxes on Capital; 14.16 Inheritance and Gift Tax Treaties; 14.17 DTAs and Entertainers and Sportspersons; 14.18 Comparison Table of OECD and Un Treaties; Volume 3; 15.
History and Context to UK Pensions: 15.1 Registered Schemes Post 6 April 2006 (Termed A Day); 15.2 Pre A-Day Pensions; 15.3 Post A-Day Rules; 15.4 Lifetime Allowance; 15.5 Cross-Border Matters; 15.6 Inheritance Tax; 15.7 Qualified Recognised Overseas Plans (QROPS); 16.
Filing, Self-Assessment and Discovery Assessments: 16.1 Approach of this Chapter; Part 1: Introduction; 16.2 Introduction to and Purpose of this Chapter; Part 2: Miscellaneous Excursus; 16.3 Some Matters Not Obvious Or Always Easily Discovered; Part 3: Self-Assessment for UK Tax; 16.4 Self-Assessment for UK Direct Tax – the Legal Framework; 16.5 VAT; 16.6 Miscellaneous Matters; Part 4: Practical Issues; 16.7 Practical Issues; 16.8 Table on Self Employment Deductions; 16.9 Disclosure of Tax Avoidance Schemes (“Dotas”); Part 5: Related Non-Tax Filings, Registration of Overseas Entities; 16.10 Related Non Tax Filings Etc.; 16.11 Registration of Overseas Entities; 16.12 Annexe; 16.13 Unexplained Wealth Orders; 16.14 Sanctions Enforcement; 16.15 Sanctions Measures; Appendix 1: Some Questions to Ask When Drafting A White Space Disclosure; Appendix 2: Checklist of Useful Information Etc. to Have for Tax Year 20xx; 17.
Miscellaneous and Practical Issues: 17.1 Introductory Matters; 17.2 Testimonials; 17.3 The 2017 Change; 17.4 Prizes and Winnings, Lottery Funding Etc.; 17.5 Enforcement of Foreign Tax Debts – “The Revenue Rule”; 17.6 Other Miscellaneous and Practical Matters; 17.7 Conclusion; 18.
VAT and ESPS - A Miscellany: 18.1 Introduction; 18.2 An Outline Reminder on the Charge to UK VAT; 18.3 Place of Supply; 18.4 The Reverse Charge; 18.5 Some Illustrative Case Law - Fees and Football Agents; 18.6 Scope, Exemptions and Zero-Rating; 18.7 Input Tax; 18.8 The Flat Rate Scheme; 18.9 Registration Etc.; 18.10 Royalties and Licensing; 18.11 Dual Representation and Football Agents; 18.12 The Dual Representation Document - Some Comments; 18.13 Conclusion; Appendix 1: Dual Representation Document; 19.
What if Things Go Wrong?: 19.1 Introduction; 19.2 Reputational Risk; 19.3 Overview of Enquiries; 19.4 HMRC Codes of Practice; 19.5 Sources of Information for HMRC; 19.6 Requirements for a Valid Enquiry; 19.7 Handling an Enquiry; 19.8 Legal Professional Privilege (“LPP”); 19.9 Overview of Tax Litigation Etc. Chances of Success; 19.10 The FTT; 19.11 Dealing with a Dispute; 19.12 Application for a Closure Notice; 19.13 Principles: Summary; 19.14 Appeals to the First-Tier Tax Tribunal; 20.
Conclusion: 20.1 General; 20.2 Matters to Consider; 20.3 Tables and Appendices Etc.; 20.4 Appendices; 20.5 Checklists; 20.6 Additions to this Chapter; 21.
Case Study– Tax for Entertainers and Sports Persons - Artistry, Wizardry and Tax?: 21.1 Introduction; 21.2 Case Study Factual Background; 21.3 Consideration of the Various Matters in the Case Study