Policy paper

The Major Sporting Events (Income Tax Exemption) (Women’s Finalissima Football Match) Regulations 2023

Published 6 February 2023

1. Who is likely to be affected

Non-UK resident players, officials and other designated individuals participating in, or otherwise involved with, the Women’s Finalissima Football Match between England and Brazil, being played at Wembley Stadium, London on 6 April 2023.

2. General description of the measure

The scope of the exemption covers income directly related to participating in the match and income directly related to services and duties performed specifically for the match. Payers of such income will not be subject to the withholding tax obligations that would otherwise apply.

The exemption applies to certain individuals who have been accredited by UEFA (the Union of European Football Associations) for the purposes of the Women’s Finalissima Football Match if they are not resident in the UK for tax purposes and earn income in connection with this UK-hosted match.

This includes those individuals whose tax residence is split between the UK and another country in tax years 2022 to 2023 and 2023 to 2024 where such income arises in the part of the year when they are not UK resident.

3. Policy objective

The government is committed to making the UK an attractive location to host international world-class sporting events. The granting of an Income Tax exemption supports this objective where the event in question is internationally mobile and considered to be of world class status.

In the absence of the exemption, subject to the terms of any applicable double taxation treaty, the affected non-UK resident individuals would be fully taxed on their income arising in connection with the UK-hosted Women’s Finalissima Football Match, and non-UK resident sportspersons would also be taxed on a proportionate share of their worldwide sponsorship income.

Payers of income to non-UK resident sportspersons and entertainers would be liable to withhold UK tax from their payments. This would make the UK less attractive as a host for international sporting events.

4. Background to the measure

This is a one-off match to celebrate the partnership between UEFA and their South American counterpart, CONMEBOL (The South American Football Confederation).

The match is scheduled to take place on 6 April 2023 at Wembley Stadium in London and will see the current holders of the Women’s ‘European Football Championship’, England play the current holders of the Women’s ‘Copa America’, Brazil.

5. Detailed proposal

5.1 Operative date

The Major Sporting Events (Income Tax Exemption) (Women’s Finalissima Football Match) Regulations 2023 will come into force on 1 April 2023. Only individuals earning income liable to tax from duties or services performed between 2 April and 7 April 2023 inclusive will be affected.

5.2 Current law

The legislation outlining the statutory basis for the taxation of employment income for non-UK resident employees, including sportspersons and entertainers, is provided by section 27 of the Income Tax (Earnings and Pensions) Act 2003.

The legislation for self-employment income is provided by section 6(2) of the Income Tax (Trading and Other Income) Act 2005, with specific legislation applicable to visiting performers at section 13 of the Income Tax (Trading and Other Income) Act 2005.

In relation to sportspersons and entertainers, relevant withholding tax provisions are set out in section 966 of the Income Tax Act 2007 and the Income Tax (Entertainers and Sportsmen) Regulations 1987 (SI 1987/530).

These regulations provide that the payer of the visiting entertainer or sportsperson is required to deduct the basic rate of Income Tax from any payments made. This withheld tax is then paid to HMRC in the quarterly returns submitted by the payer.

A non-UK resident entertainer or sportsperson is required to complete a Self-Assessment return if they have paid too little tax on the payments received. They also complete a return if they believe too much tax has been withheld and a repayment is due.

The legislation that gives the power to provide for an exemption from Income Tax and Corporation Tax is at section 48 of the Finance Act 2014. This states that where a major sporting event is to be held in the United Kingdom, HM Treasury may make regulations providing for exemption from Income Tax and Corporation Tax in relation to the event.

5.3 Proposed revisions

The Major Sporting Events (Income Tax Exemption) (Women’s Finalissima Football Match) Regulations 2023 provide for an exemption from Income Tax on income earned in the UK by certain non-UK resident individuals in connection with the UK-hosted Women’s Finalissima Football Match.

The exemption applies to income received by non-UK resident accredited players and officials and other non-UK resident accredited individuals for relevant duties or services performed in connection with the UK-hosted Women’s Finalissima Football Match provided that the income arises in respect of duties or services performed between 2 April and 7 April 2023 inclusive.

Regulation 2 defines ‘accredited person’, ‘Finalissima’, ‘income’ and ‘UEFA’ for the purposes of the regulations.

Regulation 3 provides that accredited non-resident individuals do not have to pay Income Tax on their income where it is earned in respect of duties or services performed in the UK between 2 April and 7 April 2023 in connection with the UK-hosted Women’s Finalissima Football Match and in pursuance of the specific role in respect of which the individual has been accredited.

It also defines the condition of non-residence in relation to applying the exemption and disapplies the withholding tax requirement contained in section 966 of the Income Tax Act 2007.

5.4 Summary of impacts

Exchequer impact (£ million)

2022 to 2023	2023 to 2024	2024 to 2025	2025 to 2026	2026 to 2027	2027 to 2028
—	—	—	—	—	—

The final costing will be subject to scrutiny by the Office for Budget Responsibility and set out at the next fiscal event.

Economic impact

This measure is not expected to have any significant economic impacts.

Impact on individuals, households and families

This measure only affects non-UK resident players, officials and other designated individuals in a business context participating in, or otherwise involved in, the UK-hosted Women’s Finalissima Football Match.

There is expected to be no impact on family formation, stability, or breakdown.

Equalities impacts

It is not anticipated that there will be impacts for those sharing protected characteristics.

Impact on business including civil society organisations

This measure is expected to impact on approximately 700 non-UK resident players, officials and other designated individuals within a business context who are participating in, or otherwise involved with, the UK-hosted Women’s Finalissima Football Match.

The exemption means that these individuals will not be subject to UK Income Tax on income in connection with those matches where such income arises in respect of their activities in the UK between 2 April and 7 April 2023.

They may still be liable to tax on this income in the countries in which they are resident.

UK resident competitors will not benefit from the exemption.

One-off costs will include familiarisation with the changes. There are not expected to be any continuing costs.

Customer experience is expected to stay broadly the same as this measure is around exempting eligible individuals to Income Tax.

This measure is not expected to impact businesses or civil society organisations.

Operational impact (£ million) (HMRC or other)

It is not expected that implementing this change will incur any additional costs for HMRC.

Other impacts

Other impacts have been considered and none have been identified.

6. Monitoring and evaluation

This measure will be kept under review through communication with affected taxpayer groups.

7. Further advice

If you have any questions about this change, please contact Aidan Close on telephone at 03000 585 255 or email: aidan.close@hmrc.gov.uk.

8. Declaration

Victoria Atkins MP, Financial Secretary to the Treasury has read this tax information and impact note and is satisfied that, given the available evidence, it represents a reasonable view of the likely costs, benefits, and impacts of the measure.