Isn't sport taxing? The taxation of sports professionals post-Agassi

Cassidy, Julie and Sykes, Andrew 2007, Isn't sport taxing? The taxation of sports professionals post-Agassi, Revenue law journal, vol. 17, no. 1, pp. 1-31.

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Title Isn't sport taxing? The taxation of sports professionals post-Agassi
Author(s) Cassidy, Julie
Sykes, Andrew
Journal name Revenue law journal
Volume number 17
Issue number 1
Start page 1
End page 31
Publisher Bond University
Place of publication Gold Coast, Qld.
Publication date 2007
ISSN 1034-7747
Summary In Agassi v Robinson (Her Majestyʹs Inspector of Taxes), a majority of the House of Lords found that payments under two sponsorship contracts between a company owned and controlled by Mr Andre Agassi, (Agassi Enterprises Inc) and Nike Inc and Head Sport AG were assessable under UK tax law. This was so despite (i) none of the parties to the contracts was resident, nor domiciled, in the United Kingdom and (ii) none of the payer companies conducted business, directly or indirectly, through branches/agencies in the United Kingdom. The article considers whether the Australian Taxation Office could similarly assess non‐resident sports‐persons, like Mr Agassi, personally, and/or entities they control, on payments made under sponsorship agreements with a company such as Nike Inc. While the preferable view is that such payments are not sourced in Australia, Australian source rules are so ill defined that there is some basis for asserting such payments are sourced in Australia.

Language eng
Field of Research 180125 Taxation Law
HERDC Research category C1 Refereed article in a scholarly journal
ERA Research output type C Journal article
Copyright notice ©2007, Julie Cassidy
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