IBA Annual Conference Paris 2023
29 Oct - 3 Nov 2023
Room 253, Level 2
Session information
Doing business anywhere and nowhere: taxation of athletes, entertainers and e-sport
Monday 30 October (1615 - 1730)
Room 253, Level 2
Committee(s)
Taxation Section
(Lead)
Private Client Tax Committee
Taxes Committee
Description
This panel will discuss the latest updates of the tax environment of international athletes, entertainers and explore the extent of which the existing rules may apply to new digital performers:
- Update on attitude of tax authorities and courts on tax residence of international athletes and entertainers, on international image rights structuring, and on various exemption regimes.
- Revisit the scope of entertainers and athletes for tax treaty purposes (through article 17 OECD MTC) mainly in light of new activities on digital activities carried on by e-gamers, influencers and celebrities for instance.
- Revisit the rules of sourcing and allocation between States with performance rendered in different States (international tournaments) with a special focus on e-games and digital activities for tax treaty purposes.
Session / Workshop Chair(s)
| Marco Cerrato | Maisto e Associati, Milan, Italy |
| Michel Collet | CMS Francis Lefebvre Avocats, Neuilly-sur-Seine, France |
Speakers
| Ramona Azzopardi | WH Partners, Ta' Xbiex, Malta |
| Jack Bernstein | Aird & Berlis, Toronto, Ontario, Canada |
| Paul Sczudlo | Withers Bergman, Los Angeles, California, USA |
| Sonia Velasco | Cuatrecasas, Barcelona, Spain |