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Leveling the Playing Field: A Separate Tax Regime for International Athletes

42 Pages Posted: 25 Apr 2011  

Andrew D. Appleby

affiliation not provided to SSRN

Date Written: April 20, 2011


Taxation of international athletes is a failure. The lack of a single, consistent regime results in substantial enforcement difficulties for tax administrators as well as a massive compliance burden and potential double taxation for athletes. International athletes’ unique characteristics necessitate a separate tax regime. Athletes are extremely mobile and transient taxpayers and are often among the most highly compensated individuals in the world. They can earn substantial sums of money during very short periods in a particular country. And athletes often have vast freedom to decide where to reside and where to perform. The implications of this broken tax system run very deep due to the increasing commercialization and popularity of professional sports around the globe.

The purpose of this Article is threefold. First, to compare how six significant countries - the United States, the United Kingdom, Germany, Spain, Brazil, and China - currently deal with the inherent problems of taxing extremely mobile, transient, high-income taxpayers with diverse income. Second, to illustrate that each country takes a very different - and often very convoluted - approach that has resulted in confusing, complex, and inconsistent regimes. And finally, to propose a solution that will benefit tax administrators and athletes alike. This Article presents a rough blueprint for a feasible regime that is simple, effective, efficient, and extremely beneficial for both tax administrators and athletes. Now the sports world will have to wait and see if any countries are willing to play ball.

Keywords: tax, sports, international, athlete, sportsmen, United States, United Kingdom, Germany, Spain, Brazil, China

Suggested Citation

Appleby, Andrew mname, Leveling the Playing Field: A Separate Tax Regime for International Athletes (April 20, 2011). Brooklyn Journal of International Law, Vol. 36, No. 2, p. 605, 2011. Available at SSRN:

Andrew Appleby (Contact Author)

affiliation not provided to SSRN ( email )

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