Post by Gurdeep Singh Dhanjal

Sport/Media/Entertainers international tax advisor

Now that the 2026 FIFA World Cup has officially kicked off, we thought it would be a good opportunity to share some of our recent experiences supporting players, pundits and governing bodies operating across the host nations.   We understand FIFA are securing a US federal income tax exemption (as already agreed with the Mexican and Canadian tax authorities) and whilst the introduction is welcome, there are still several important considerations:   ⚽ Tax filing obligations may still apply ⚽ US State taxes may still be relevant (some states do not recognise federal exemptions or Double Tax Treaty (DTT) benefits). ⚽ Social security liabilities may arise ⚽ Personal income earned (such as endorsement, sponsorship and commercial activities), could be subject to local taxation.   A practical point; the host nation tax authorities have agreed a prize money income apportionment - this should determine how income should be sourced across three host countries.   From a player perspective, DTT’s can provide valuable relief where remuneration falls below specified thresholds, although their application is often limited. Under the US–UK Double Tax Treaty, no US federal withholding tax is generally due where gross income (and expenses) does not exceed $20,000.   Pundits, Podcasters and Influencers present a different set of considerations. Unless specifically treated as entertainers under a relevant treaty, they may not fall within the same taxing provisions as players.   Depending on the nature of their engagement and whether they are engaged as employees or self-employed contractors, treaty protection and Social Security agreements can often play a significant role in determining their tax position.    We have been busy advising our clients who have filing requirements in US for providing services above the $20,000 de minimis during the world cup.   Finally, football is not the only sport dominating the 2026 summer of sport 2026 as tennis, formula one, cricket, athletics, cycling (and many more!) are all on at some point for fans to enjoy. Accordingly, we have written an article relating to foreign tax as it applies to both footballers but also other sportspeople in general. It covers double tax relief and minimisations and worth a read 😊 !   Martin Smith James Lion Daniel Rudbeck Anna Youle Finlay Price Emily Price Joe Troth Thomas Hemmings HW Fisher, part of the Sumer Group #FIFAWorldCup #SportsTax #GlobalMobility #InternationalTax #SportsBusiness https://lnkd.in/eyD5Q9xi

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