City AM quotes Sophie Dworetzsky on the potential impact of non-dom changes on high-profile footballers

According to a number of commentators, there is a possibility that many high-profile football players may choose to leave the UK for other jurisdictions if the government continues with its plans to scrap the non-dom tax status in the upcoming Budget.

Changes to the way tax is paid on overseas earnings could prove “an own goal” if they cause players to leave the English top flight when they come into force in April next year.

A non-dom is a UK resident whose permanent home is outside of the country for tax reasons. So for current Premier League footballers, monies earned beyond the UK and paid into foreign bank accounts – such as international appearance fees or image rights – are not taxed in the UK, but Premier League wages in a UK bank account are.

However, changes to this system - which could be reiterated in Rachel Reeves’ Budget later this month - would see all earnings taxed by the UK Government, often at a higher rate than they would pay in other jurisdictions.

Sophie Dworetzsky, Partner in our Private Client team, comments on the topic in an article for City AM:

For those who have already been in the UK for four or more years as of 6 April 2025, any offshore income and gains will generally be fully taxable [...] This contrasts with the present position where offshore income and gains of resident non-doms are not taxed unless brought onshore generally.

"It is likely that many internationally mobile footballers will have established trusts and companies outside the UK which hold investments on which they are not currently taxed. This will change markedly on 6 April so that if they can benefit from the structures they will be taxed on income and gains arising within them [...]

"Separately, under the current proposals, once a footballer [or anyone else] has been a UK resident for 10 years their worldwide assets will be within the UK inheritance tax net for another 10 years [...] While 10 years is a long time in football, it is likely fair to assume that many internationally mobile footballers will move in advance of a 10-year timescale if they would otherwise have stayed [...]

"All of this means clubs may find it easier to attract new residents and that footballers may arrive in the UK with a plan to leave after not much more than a few years here.

"The lack of an attractive longer-term tax regime for individuals moving to the UK from abroad might be regarded as an own goal.

Read the full article in City AM here.