UK tax rules for non-resident entertainers and sportspeople

If you’re a foreign athlete or performer who is booked to perform and your UK income is expected to exceed your personal allowance (£12,570 for 2021/22), the payer must deduct withholding tax from the payment. The Foreign Entertainers Unit will only issue tax deduction certificates in your name and the total payment can be made up of both performance income and reimbursed expenses.

Tax on UK performances

For all performances in the UK, 20% tax is withheld on performance fees, taxed when the performance is undertaken.

Any expenses that are reimbursed also need to have tax withheld, with the reimbursement being the net value to you, the performer. This means that the payer must ‘gross up’ the expense and calculate the withholding tax on the gross amount.

As an entertainer or sportsperson, if you have UK performance income in excess of the Basic Rate band (£50,270 for 2021/22), the withholding tax may not be enough to cover your tax liability and you will be required to complete a UK tax return. In such cases, direct expenses that are incurred wholly and exclusively for the purpose of your business are deductible against your income. There is also scope to apportion an amount of the worldwide indirect costs based on the number of performances in the UK.

One significant point to note is that payments made to a seemingly unconnected entity, such as a service company, do not affect the UK tax treatment if it is controlled by you, the foreign performer. In such a case, the income is attributed directly to you and subject to UK income tax. Double taxation relief can very often be claimed, where available under the rules of your country of residence, for the UK tax paid against your domestic company or individual tax liability.