Football Taxation - Players' Perspective: Taxation of the Image Rights of the Player: Rules and Principles

Argentina

The assignment of image rights by an athlete is subject to the general rules of income tax.

If the income from image rights is part of an employment relationship, it could potentially be classified as salary and, as such, subject to the same rules as income from dependent employment. If, on the other hand, such payments are agreed upon independently, through a specific contract or clause, they are considered second-category income (i.e. royalties) attributable to the football player.

When image rights are assigned for exploitation to a legal entity distinct from the athlete, the tax treatment of that in its country of residence must be analyzed. It is also important to consider the athlete’s relationship with the entity, as the treatment will differ depending on whether the income is classified as royalties or dividends (in the case of the athlete being a shareholder).

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