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Real Madrid and Borussia Dortmund receive tax breaks in Great Britain for the Champions League final
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Real Madrid and Borussia Dortmund receive tax breaks in Great Britain for the Champions League final

MADRID, SPAIN – MAY 08: Jude Bellingham of Real Madrid celebrates his team's victory and reaching the final of the UEFA Champions League after the UEFA Champions League semi-final second leg match between Real Madrid and FC Bayern Munich at Estadio Santiago Bernabeu on May 08, 2024 in Madrid, Spain. (Photo by Clive Brunskill/Getty Images)

MADRID, SPAIN – MAY 08: Jude Bellingham of Real Madrid celebrates his team’s victory and reaching the final of the UEFA Champions League after the UEFA Champions League semi-final second leg match between Real Madrid and FC Bayern Munich at Estadio Santiago Bernabeu on May 08, 2024 in Madrid, Spain. (Photo by Clive Brunskill/Getty Images)

Jude Bellingham, Jadon Sancho and their Real Madrid and Borussia Dortmund teammates will not have to pay British tax on the proceeds from the Champions League final at Wembley.

Bellingham’s Real Madrid and Sancho’s Dortmund secured their place in next month’s season-ending clash in London by defeating Bayern Munich and Paris Saint-Germain in the semi-finals this week.

Normally, the UK levies income tax on income, including from image rights, bonuses and endorsement deals, for any time that expatriate athletes compete in the UK, for example at Wimbledon or the Open.

However, special exceptions apply for certain major events, and the Champions League final has been added to a list that previously included the 2012 London Olympics and the 2022 Women’s European Championship.

“This will be a welcome relief for all non-UK residents attending the 2024 Champions League final,” said Lee Stott, tax partner at accountancy and advisory firm Azets.

“When it comes to sporting events for non-UK citizens, the UK is quite unique in that we consider income from events held in the UK to be taxable UK income, as well as any income related to an athlete’s image rights, bonuses and endorsement deals.

“Non-resident football players and coaches come to the UK to carry out a ‘relevant activity’ – in this case a sporting performance – and this is captured by the ‘Artists and Sportsmen Article’ in the various tax treaties the UK has with countries around the world.

“For example, a Spanish football player is liable to tax in Spain and that is why we look at Article 16 of the UK-Spain tax treaty. It states that income derived by a Spanish resident sportsman relating to activities carried out in the UK can be taxed in the UK.

“Therefore, part of the Spanish salary relating to UK working days would be taxable in the UK without this exemption offered by the Treasury. Non-playing staff are also exempt from tax as employees under another article of the tax treaties and therefore do not require a special exemption.

“Most industrialized countries in the world have some kind of tax system that covers athletes and entertainers. In the UK, the variant is called the Foreign Entertainers Unit (FEU) system.”

The exemption applies to players and staff of Real Madrid and Dortmund for up to six days around the Champions League final on June 1.

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