Taxation of Sports Players at 2024 Euro Football & Olympics

Impact of Article 17 for athletes competing in Germany & France this summer

Content:

1. Introduction
2. Special provision in tax treaties: Article 17
3. National (withholding) tax rules
4. Taxation in the residence state and elimination of double taxation
5. Policy since 2010 seems to come to an end
6. Final Words

Summary

At the two major sports event this summer, the EURO football in Germany and the Olympics in France, also taxation plays a role. This article studies the tax aspects of the football players and the athletes. For 13 years, both the UEFA and IOC have forced the organizing states to allow a tax exemption at source to the sports players, but this seems to be changed. Both Germany and France would like to use their rights under Article 17 of their tax treaties. But this would create much administrative work and the risk of double taxation. Although for some states with the exemption method to eliminate double taxation, their players could profit from double non-taxation. It shows that Article 17 is a disturbing tax factor. 

1. Introduction 

Two major sports events attract the attention this summer: the European Championships football in Germany (14 June – 14 July) and the Olympics in Paris, France (26 July – 11 August). Sports at the highest levels with fans supporting national teams and players, where wins and defeats lie closely together. This is sports how it should be. 

Also at the financial side, both the EURO and the Olympics are top level events. Ticket sales in the stadiums, television rights for national broadcasters, advertisement and other sponsors and the sale of merchandise. Altogether, this creates high financial budgets for both sports events. 

With financial earnings, also taxation becomes a relevant factor. This article will focus on the taxation of the key actors at these events: the football players at the EURO in Germany and the athletes at the Olympics in France. The host states have the right to tax the income of these players, but how they use this right is relevant for the eliminate of double taxation in the resident states. 

Since 2010, both the Olympics and the major football tournaments have had tax exemptions…

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Author

Dick Molenaar

Tax Adviser, All Arts Tax Advisers & Researcher, the Erasmus University, Rotterdam, the Netherlands  

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