Summer Transfer Window 2026: What Latin American footballers need to know about UK tax before signing with a Premier League Club

Signing for a Premier League club in the UK is the dream - but a move to the UK carries serious UK tax consequences that must be planned for before any contract is signed. This article outlines some of the key UK tax and structuring considerations for Latin American (Latam) footballers and their families relocating to the UK.

Getting this wrong is expensive; getting it right requires joined-up specialist cross-border advice, ideally before the player arrives in the UK.

UK tax residence

A Latam footballer who relocates to the UK will almost certainly become UK tax resident.  By default, this means that they are subject to UK income tax and capital gains tax (CGT) on worldwide income and gains - salary, bonuses, signing-on fees, endorsement income, investment returns - wherever they arise.

The UK tax year runs from 6 April in one year to 5 April in the next.  A player who moves to the UK in (say) July may therefore have already been UK tax resident for several months before their arrival. However, if they start playing full-time for a club, they may qualify for 'split year treatment' - in which case they are treated as UK resident for most tax purposes only from the date they start working full-time in the UK. Understanding the date from which UK residence starts, and the breadth of their UK tax exposure, is the first step.  

Transfer fees present particular complexities for footballers as payments often span the period before and after arrival in the UK, and often also include a contingent / performance-related element. The question then arises as to when the income is treated as arising for UK tax purposes and to what extent it can be said that the payments relate to duties performed in the UK.

Qualifying new resident (QNR) regime - and its limits

A footballer moving to the UK may qualify for the UK’s “Qualifying New Resident” regime (the QNR regime). The QNR regime is a new 4 year special tax regime which replaced the previous “non-dom” regime from 6 April 2025.

A player who qualifies as a QNR may claim foreign income and gains relief for the first 4 consecutive tax years of UK tax residence.  Under the QNR regime, most types of foreign income and foreign gains are exempt from UK income tax and CGT, even if remitted to the UK.

This is a valuable and attractive tax relief.  However - and this is crucial for footballers - “performance income” is carved out and does not benefit from QNR relief.  Performance income is broadly defined and catches not only salary and match fees, but also endorsement and image rights income connected to the player’s sporting activities.  A point to watch is that if a non-UK company earns commercial fee income and pays it out as a dividend, that dividend may still be treated as performance income - and therefore fully taxable in the UK - even though it is foreign income.  

In practice, this carve out means that a substantial proportion of a footballer’s non-UK earnings may be fully taxable in the UK from day one at up to 45%. Careful analysis of existing structures is essential, and restructuring how image rights and investments are held may be necessary, to maximise QNR relief on passive or non-performance income.

There are two other features of the QNR regime of which footballers should be wary:

• The QNR regime is “use it or lose it”.  In other words, the 4 year period runs from the first year of UK residence, irrespective of the player’s residence status in the following 3 years.  This means that a player who comes to the UK for a single season (e.g., on loan to a UK club) could lose access to the remaining 3 years of relief if they later return to the UK outside the 4 year window.  
• For most footballers in the Premier League, a proportion of their duties for the UK clubs are performed outside the UK – for example, away matches in European club competitions.  They may also have foreign earnings from playing for their national team.  Earnings attributable to non-UK duties can benefit from relief under the QNR regime, but this is subject to a cap (the lower of £300,000 per year or 30% of the player’s total employment income).  

Footballers (and their wider advisory teams) should be aware of such intricacies and traps so that they are not caught out.

Non-UK companies, image rights and UK anti-avoidance rules

UK tax residence and permanent establishment of non-UK companies

Many Latam players hold their image rights through a company set up in their home countries. Brazilian footballers, for example, usually hold their image rights through a company set up in Brazil. A key risk is that this company could itself become subject to UK tax if important decisions about the company are made in the UK - for example, by the player or a family member who has moved to the UK and acts as a director (or a shadow director). Without advice, this outcome may have already arisen without their knowledge.

If the company is treated as UK tax resident, its worldwide profits could be taxed in the UK at 25%.  Even if the company is managed outside the UK, it may still have a taxable presence in the UK if it carries on business here through, for example, a fixed place or dependent agent. These risks are particularly acute for footballers, as commercial contracts are often negotiated and concluded in the UK.

If a non-UK company also remains resident under local law, it may be subject to tax in both jurisdictions. Where a double tax treaty between the UK and the player’s home country is in force, relief may be available - but the scope of relief will depend on the terms of the particular treaty. Where no treaty is in force (as is currently the case between the UK and Brazil), relief may be available under domestic law but this may depend (for example) on the source of the income in question.  

Understanding the interaction between the UK and local tax rules, together with any treaty overlay, is essential and requires coordinated cross-border advice from the outset.

Image rights

Image rights are a major revenue stream for footballers. The traditional structure involves the player licensing their image rights to a company - often established outside the UK - which then contracts with the club and commercial sponsors to exploit those rights.

UK rules that can "look through" the company

The UK has anti-avoidance rules that, depending on the circumstances, can effectively ignore the company structure and tax the income directly in the player's hands, at rates of up to 45%. In some cases, this can even apply to income earned under arrangements put in place before the player arrived in the UK. QNR relief does not protect income attributed under these rules to the extent that the income is or represents performance income, so income from sponsorship / endorsement contracts may be caught, even during the first 4 years of UK residence.

In addition, where a player's rights are held by a non-UK company but need to be sub-licensed to a UK company (for example, to enable the UK company to enter into a club-related image rights contract), the terms of any sub-licence must be carefully considered - charging a fee risks triggering these UK anti-avoidance rules, while not charging one may invite challenge from local tax authorities.

Upcoming changes to image rights taxation

Premier League clubs typically require club-related image rights payments to be made to a UK incorporated company. From 6 April 2027, all image rights payments connected to an employment will be treated as taxable employment income and subject to income tax at up to 45% (and national insurance contributions at 2%) on the player personally, even if received by the company. However, this change is expected to apply only to club-related image rights payments.  Third party commercial sponsorship income is not expected to be caught.

The complexity of the UK tax rules in this area combined with upcoming rule changes mean that it is more important than ever to take advice in relation to how a player’s image rights are held, and any restructuring that may be advisable, to maximise tax efficiency in both the UK and any other relevant jurisdictions. Putting an effective and tax-efficient rights-holding structure in place is one of the most valuable things that can be done before a player arrives in the UK.

Exit planning – future proofing the structure 

Footballers’ careers are mobile. Therefore, any structure put in place on arrival should be designed so that it can be reorganised or collapsed efficiently when the player leaves the UK. For example, the terms and duration of any image rights licences or sub-licenses should be considered with a future departure in mind - a long-duration or irrevocable licence may have a goodwill value, and if a company which holds the right is or has become UK tax resident (because its central management and control is exercised from the UK), it may face an “exit tax” when the player departs and management moves abroad, triggering a corporation tax charge at 25% on any built-in gain - including any goodwill value.

Another potential pitfall arises where a player leaves the UK, collapses their image rights structure, extracts accumulated profits and subsequently becomes UK resident again within 6 tax years of departure.  In such circumstances, the UK can claw-back gains and certain forms of income (e.g. dividends from certain companies) realised during the period abroad, taxing them as if they had arisen in the year of return, regardless of whether they derive from pre- or post-departure profits. In practical terms, a player who moves to, say, Spain for two or three seasons and then signs for another Premier League club, may face a large UK tax bill on profits they thought they had extracted tax-free.

Structures should therefore be designed with tax-efficiency both on entry and on exit in mind.

Inheritance Tax (IHT)

Individuals arriving in the UK are not immediately subject to UK IHT on overseas assets. However, after 10 consecutive years of UK residence, a player will become subject to IHT at 40% on worldwide assets - a critical threshold for younger players who may spend a decade or more at English clubs and who may hold significant assets in their home countries or elsewhere. IHT is not only a tax on death, it can also apply to certain lifetime gifts and on gifts into trust.

Once the 10 year threshold is crossed, a “tail” applies after leaving the UK: the player remains within scope of UK IHT for between 3 and 10 tax years after departure, depending on the length of prior residence. However, the tail can be mitigated depending on the jurisdiction to which the player moves; and other important exemptions and reliefs can mitigate the effects of IHT exposure in practice.

Immigration

A player relocating to the UK will need appropriate visa arrangements. This is particularly important for players relocating together with their families – who can often find it difficult to quickly secure a long-term visa.

Specialist immigration advice should therefore be taken alongside tax advice at the outset. We can advise players and their families on the most suitable visa options for entry into the UK.

Getting it right

A Latam footballer contemplating a Premier League move should take specialist advice – covering tax, IP, corporate / commercial and immigration - before signing any agreement. Getting the right structure in place before arrival in the UK can make all the difference. Pre-arrival planning is not optional - it is the single most effective lever available to manage the tax cost of playing in the Premier League.

Charles Russell Speechlys advises Latam and international footballers on the full range of tax and legal issues arising on a transfer to the UK. Our team works closely with players’ family offices and local advisers in Latin America to deliver integrated, cross-border solutions. For further information please contact Rafael Boccatto and Jonathan Rothwell.