Volume 1 Publisher''s Note Foreword Abbreviations and Glossary Preface 1 Introduction 1.1 Purpose and General Matters 1.2 Structure of this Book 1.3 What Is Meant By ESPs (Entertainers and Sportspersons) for the Purposes of the Book 2 The Relevant UK Taxes and Levies 2.1 Introductory Matters 2.2 UK Income Tax - an Overview 2.3 UK Capital Gains Tax- an Overview 2.4 UK Corporation Tax - an Overview 2.

5 IHT 2.6 VAT 2.7 NIC - National Insurance 2.8 Annexe - Client Questions Appendix 1: UK Income Tax ("IT") - General Appendix 2: UK Corporation Tax - General Appendix 3: Transfer Pricing and the UK Appendix 4: Diverted Profits Tax ("DPT") Appendix 5: UK VAT - Outline Reminder on VAT Appendix 6: Some Matters for Consideration for Any Jurisdiction. 3 UK Tax and Connecting Factors 3.1 Introduction 3.2 "Source" 3.3 "Residence" 3.

4 Domicile Appendix 1: Summary SRT Appendix 2: Split Year Treatment Appendix 3: Definitions and Clarifications Appendix 4: Initial Checklist for Residence and Related Matters Appendix 5: Initial Domicile Questionnaire Appendix 6: Offshore Income and Gains and the Remittance Basis Appendix 7: March 2024 Budget Remittance Etc. Changes and Later Announcements 4 Ways of Carrying on the Business for an Actor or Sportsperson 4.1 Introduction 4.2 UK Tax on Different Ways of Carrying on the Business 4.3 Liability to United Kingdom Tax of Entertainers and Sportsmen 4.4 Annexe 4.5 Trade/Profession Or Employment? 4.6 Clothing 4.

7 Medical Expenses Appendix 1: Comparative General Table on Tax of Entities With UK Resident Owner 5 Points, Residuals and Post Cessation Receipts 5.1 Introduction 5.2 Profit and Earnings Recognition - Some General Comments 5.3 Visiting Performers 5.4 Post Cessation Receipts 5.5 Deemed Cessation 5.6 What About Companies? 5.7 Transfers Etc.

5.8 Tailpiece 6 Anti-Avoidance 6.1 Introduction 6.2 UK Approach to Avoidance 6.3 The Settlement Provisions 6.4 Capital Gains Tax - Some Avoidance Provisions 6.5 Transactions in Securities 6.6 Sale of Occupation Income 6.

7 Tax Havens Appendix 1: Interpretation and Definitions Etc. Appendix 2: Protected Trusts 7 Administration and Collection of Tax 7.1 Introduction 7.2 What Is HMRC? 7.3 Judicial Review ("JR") 7.4 Further Materials 7.5 Legitimate Expectation Volume 2 8 Foreign Self-Employed ESPs 8.1 Introduction 8.

2 General 8.3 ITA Provisions 8.4 The 1987 Regulations Appendix 1: Simplified Flowchart on Deductibility Appendix 2: Some Definitions of Relevant Words and Phrases Appendix 3: Schedule 11 Entertainers and Sportsmen Appendix 4: HS 3032024 9 Royalties 9.1 Introduction 9.2 Royalties 9.3 UK Direct Tax Charge on Royalty Income 9.4 Withholding Tax and Royalties 9.5 Excursus on Annual Payments 9.

6 UK Withholding Tax--Overview 9.7 Withholding Tax on Payments Relating to Intellectual Property Appendix 1: Some Useful HMRC Extracts 10 Endorsement, "Image Rights", Appearances and the Like 10.1 Introduction 10.2 "Image Rights" and the Like 10.3 Guernsey 10.4 Image Rights in Practice 10.5 Endorsement, Sponsorship Etc. 10.

6 Design and Promotion 10.7 Personal Appearances 10.8 NFTs Appendix 1: Breach of Confidence Appendix 2: The Economic Torts and Related Matters Appendix 3: Guernsey Image Rights 11 Particular Activities for ESPs Including Personal Branding 11.1 Introduction 11.2 Personal Branding 11.3 Establishing a Trademark Etc. 11.4 Vehicle(S) for Personal Brand 12 Intermediaries Legislation (IR5 Etc.

) 12.1 Introduction 12.2 General Matters 12.3 Relevant Criteria and Approach to Determining Employment Status 12.4 Application of Provisions to Agency Workers Chapter 7 12.5 Workers'' Services Provided Through Intermediaries to Small Clients Chapter 8 12.6 Managed Service Companies Chapter 9 12.7 Chapter 10 "Workers'' Services Provided Through Intermediaries to Public Authorities Or Medium Or Large Clients [Sections 61k-61x]" 12.

8 Conclusion Appendix 1: Employment Status Manual 13 Double Taxation 13.1 Introduction 13.2 Sources of Information and HMRC''s Views 13.3 What Is Double Taxation? 13.4 Capital Gains Etc. 13.5 Miscellaneous Matters 14 Double Tax Treaties 14.1 General 14.

2 Interpretation of Tax Treaties 14.3 Some Extracts From the OECD Model Treaty [2017] 14.4 Jurisdiction to Tax 14.5 Residence of Persons 14.6 Domicile 14.7 Activities/Sources 14.8 Source Country Taxation 14.9 Permanent Establishment (PE) 14.

10 Mobile Investment Income Under Model Treaties: Dividends, Interest, Royalties 14.11 Interest 14.12 Royalties 14.13 Capital Gains 14.14 Income From Employment 14.15 Lifetime Taxes on Capital 14.16 Inheritance and Gift Tax Treaties 14.17 DTAs and Entertainers and Sportspersons 14.

18 Comparison Table of OECD and Un Treaties Volume 3 15 History and Context to UK Pensions 15.1 Registered Schemes Post 6 April 2006 (Termed A Day) 15.2 Pre A-Day Pensions 15.3 Post A-Day Rules 15.4 Lifetime Allowance 15.5 Cross-Border Matters 15.6 Inheritance Tax 15.7 Qualified Recognised Overseas Plans (QROPS) 16 Filing, Self-Assessment and Discovery Assessments 16.

1 Approach of this Chapter Part 1: Introduction 16.2 Introduction to and Purpose of this Chapter Part 2: Miscellaneous Excursus 16.3 Some Matters Not Obvious Or Always Easily Discovered Part 3: Self-Assessment for UK Tax 16.4 Self-Assessment for UK Direct Tax - the Legal Framework 16.5 VAT 16.6 Miscellaneous Matters Part 4: Practical Issues 16.7 Practical Issues 16.8 Table on Self Employment Deductions 16.

9 Disclosure of Tax Avoidance Schemes ("Dotas") Part 5: Related Non-Tax Filings, Registration of Overseas Entities 16.10 Related Non Tax Filings Etc. 16.11 Registration of Overseas Entities 16.12 Annexe 16.13 Unexplained Wealth Orders 16.14 Sanctions Enforcement 16.15 Sanctions Measures Appendix 1: Some Questions to Ask When Drafting A White Space Disclosure Appendix 2: Checklist of Useful Information Etc.

to Have for Tax Year 20xx 17 Miscellaneous and Practical Issues 17.1 Introductory Matters 17.2 Testimonials 17.3 The 2017 Change 17.4 Prizes and Winnings, Lottery Funding Etc. 17.5 Enforcement of Foreign Tax Debts - "The Revenue Rule" 17.6 Other Miscellaneous and Practical Matters 17.

7 Conclusion 18 VAT and ESPS - A Miscellany 18.1 Introduction 18.2 An Outline Reminder on the Charge to UK VAT 18.3 Place of Supply 18.4 The Reverse Charge 18.5 Some Illustrative Case Law - Fees and Football Agents 18.6 Scope, Exemptions and Zero-Rating 18.7 Input Tax 18.

8 The Flat Rate Scheme 18.9 Registration Etc. 18.10 Royalties and Licensing 18.11 Dual Representation and Football Agents 18.12 The Dual Representation Document - Some Comments 18.13 Conclusion Appendix 1: Dual Representation Document 19 What if Things Go Wrong? 19.1 Introduction 19.

2 Reputational Risk 19.3 Overview of Enquiries 19.4 HMRC Codes of Practice 19.5 Sources of Information for HMRC 19.6 Requirements for a Valid Enquiry 19.7 Handling an Enquiry 19.8 Legal Professional Privilege ("LPP") 19.9 Overview of Tax Litigation Etc.

Chances of Success 19.10 The FTT 19.11 Dealing with a Dispute 19.12 Application for a Closure Notice 19.13 Principles: Summary 19.14 Appeals to the First-Tier Tax Tribunal 20 Conclusion 20.1 General 20.2 Matters to Consider 20.

3 Tables and Appendices Etc. 20.4 Appendices 20.5 Checklists 20.6 Additions to this Chapter 21 Case Study- Tax for Entertainers and Sports Persons - Artistry, Wizardry and Tax? 21.1 Introduction 21.2 Case Study Factual Background 21.3 Consideration of the Various Matters in the Case Study Volume 4 22 The New Residence Based Regime after Finance Act 2025 22.

1 Summary 22.2 General 22.3 The Relevant Legislation 23 Specifics: Replacement of Special Rules Relating To "Domicile" 23.1 Summary 23.2 General 23.3 Chapter 1 of Part 2 of the Act: New Rules for Foreign Income and Gains of Individuals Becoming UK Resident 23.4 Details of New Chapter 5 Part 8 ITTOIA 23.5 Section 38 - The New Overseas Workday Relief 23.

6 Schedule 8 Relief on Foreign Employment Income: Consequential and Transitional Provision 23.7 Abolition of the Remittance Basis 23.8 Application of Income Tax Acts in Relation to Deemed Employment 23.9 Rebasing of Assets for CGT for Some Former Remittance Basis Users 24 Trusts: Connected Amendments, Transitional Provision Etc 24.1 Summary 24.2 Further Review 24.3 The Legislation - Section 43 25 Inheritance Tax 25.1 Summary 25.

2 Some Relevant Legislation 25.3 Replacement of Domicile Test by Long-Term Residence Test - Section 44 FA 2025 25.4 Long Term Residence and Excluded Property Appendix 1: Annexe Appendix 2: Inland Re.