Let’s imagine that Player A of Brazilian nationality has some commercial income in Brazil. Player A signed with a club from Poland, where he played for one year, and subsequently was transferred to the club from the UK for the transfer fee of EUR 10 million. In the termination agreement between the Player and the Polish club, the parties decided that the Player was entitled to 10% net of taxes (EUR 1 million) from his transfer as soon as the Polish club received the money from the English club, which was expected after 12 months from the Player’s transfer.

In that example, Player A could potentially be considered a tax resident of Brazil, Poland and the UK at the same time, which means that his worldwide income may be taxed in those three countries simultaneously. However, he might be eligible for a set-off of taxes based on Double Taxation Treaties (DAT) between those countries.

In the given example, the Player’s A sell-on fee (EUR 1...

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