Football Taxation - Clubs' Perspective: Taxation Principles in case of a Player Loan (Corporate Income Tax and VAT) for the Club or the Player

Argentina

In the case of a player loan, the club receiving a payment will not be subject to income tax, as clubs are exempt from this tax. The transaction will also not be subject to VAT, as these are usually no subject to this tax.

But any player’s income derived from this transaction will be subject to Income Tax but not VAT.

Belgium

The loan fee paid (if applicable) will be subject to Corporate Income Tax in the hands of the lending club and correspondingly qualify as a tax-deductible expense in the hands of the paying club. Conversely, the same will apply - in the other direction - should the lending club pay a development fee for the loan.

A loan is considered a service subject to Belgian VAT (see above, the same scope of application as in the case of a transfer).

For the loan, a new employment contract will be concluded between the engaging club and the player. As...

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