Football Taxation - Players' Perspective: Is There any Favorable Tax Regime Applicable to the Players’ Image Rights? Are There any Anti-Abuse Schemes?

Argentina

There is no favorable tax regime applicable to the players’ image rights.

Although there are no specific anti-abuse rules for star companies in Argentine legislation, the general rules on economic reality can be applied (Art. 2 of the Tax Procedure Law). In this sense, the tax authority may disregard the use of “inappropriate” legal structures when they differ from the economic intent of the parties involved in a transaction. However, there are no precedents in case-law regarding this type of situation.

The anti-abuse rules provided for intermediary companies in the Double Taxation Avoidance Agreements signed by Argentina may also be applied.

Belgium

Belgian tax law provides for a general anti-abuse provision, under which the tax...

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