Athletes’ Image Rights Taxable Under VAT: Key Insights from French Conseil d’État Ruling

• Athletes’ image rights are taxable under VAT rules in France.
• Unlike models, athletes’ image rights are not part of their salary and are not exempt from VAT.
• Athletes are valued for performance, not appearance, and their image use is optional.
• Endorsement contracts for athletes lack employment subordination, making royalties taxable as services.
• Royalties depend on revenue generated, not a fixed amount, placing economic risk on the athlete.
• Athletes are considered independent from employers when licensing their image.
• Image rights contracts are separate from employment contracts and can be independently negotiated.
• Tax authority decisions can be challenged in court by professional unions representing athletes.

Source: taxand.com

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.

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