Policy paper

The Major Sporting Events (Income Tax Exemption) (2024 UEFA Champions League Final) Regulations — 2024

Published 26 February 2024

Who is likely to be affected

Non-UK resident players, officials and other designated individuals participating in, or otherwise involved with, the Union of European Football Associations (UEFA) Champions League Final football match between the two finalists, being played at Wembley Stadium, London on Saturday 1 June 2024.

General description of the measure

The exemption applies to certain individuals who have been accredited by UEFA for the purposes of the 2024 UEFA Champions League Final 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 year 2024 to 2025 where such income arises in the part of the year when they are not UK resident.

The scope of the exemption covers income directly related to:

• participating in the 2024 UEFA Champions League Final
• services and duties performed specifically for this event

Payers of such income will not be subject to the withholding tax obligations that would otherwise apply.

Policy objective

The UK government is committed to ensuring the UK continues to be 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 world class, internationally mobile and where such an exemption is a condition of the bidding process to host the event.

Previously, an Income Tax exemption was a condition of the successful UK bid to host the Birmingham Commonwealth Games in 2022 and, more recently, the Women’s Finalissima football match in 2023.

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 2024 UEFA Champions League Final. 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. The objective of the policy is to increase the attractiveness of the UK as a host for international sporting events.

Background to the measure

The UEFA Champions League is an annual club association football competition organised by UEFA and contested by top-division European clubs. It is the most-watched club competition in the world and is one of the most prestigious football tournaments in the world. The match is scheduled to take place on Saturday 1 June 2024 at Wembley Stadium in London, with the finalists to be determined after the various stages and knockout matches.

The granting of an Income Tax exemption for persons designated by UEFA was a condition of the bidding process for all countries seeking to host this Final.

The English Football Association bid to host the 2024 UEFA Champions League Final on the basis that the UK government agreed to the formal requirement of providing an Income Tax exemption if it was successful. A letter was provided to UEFA by the Financial Secretary to the Treasury at the time to confirm this.

Detailed proposal

Operative date

The Major Sporting Events (Income Tax Exemption) (2024 UEFA Champions League Final) Regulations 2024 will come into force on 27 May 2024. Only individuals earning income liable to tax from duties or services performed in the UK between 28 May and 2 June 2024 inclusive will be affected.

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 tax 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 UK, HM Treasury may make regulations providing for exemption from Income Tax and Corporation Tax in relation to the event.

Proposed revisions

The Major Sporting Events (Income Tax Exemption) (2024 UEFA Champions League Final) Regulations 2024 provide for an exemption from Income Tax on income earned in the UK by certain non-UK resident individuals in connection with the 2024 UEFA Champions League Final. The exemption applies to income received by non-UK resident accredited competitors and officials and other non-UK resident accredited individuals for relevant duties or services performed in connection with the 2024 UEFA Champions League Final, provided that the income arises in respect of duties or services performed in the UK between 28 May and 2 June 2024 inclusive.

Regulation 1 defines ‘accredited person’, ‘income’, ‘the organiser’, ‘relevant activity’, and ‘the sporting event’ for the purposes of the regulations. 

Regulation 2 also 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 28 May and 2 June 2024 in connection with the 2024 UEFA Champions League Final
• 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.

Summary of impacts

Exchequer impact (£ million)

2023 to 2024	2024 to 2025	2025 to 2026	2026 to 2027	2027 to 2028	2028 to 2029
nil	nil	—	—	—	—

This measure is not expected to have an Exchequer impact.

Economic impact

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

Impact on individuals, households and families

This measure only affects non-UK resident competitors, officials and other designated individuals in a business context participating in, or otherwise involved in, the 2024 UEFA Champions League Final. There is expected to be no impact on family formation, stability or breakdown.

This measure is expected to impact on an estimated 600 non-UK resident competitors, officials and other designated individuals who are participating in, or otherwise involved with, the 2024 UEFA Champions League Final. The exemption means that these individuals will not be subject to UK Income Tax on income in connection with this match where such income arises in respect of their activities in the UK during the exemption period. They may still be liable to tax on this income in the countries in which they are resident.

Customer experience is expected to stay broadly the same as this measure is around exempting eligible individuals to Income Tax and it does not significantly alter how individuals interact with HMRC.

Equalities impacts

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

Impact on business including civil society organisations

UK resident individuals or businesses 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 and it does not alter how businesses would interact with HMRC. 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.

Monitoring and evaluation

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

Further advice

If you have any questions about this change, please contact Raiyan Ali on email: assetsresidencepolicy@hmrc.gov.uk.

Declaration

Nigel Huddleston 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.