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Tax domicile of athletes, advantages and risks of moving it

Publication at Faculty of Law |
2023

Abstract

Athletes are a specific category of taxpayers. Due to their high global mobility, when they travel to tournaments and matches often around the world, or work in a foreign club, the question of determining their tax residence as a place where they are considered resident for tax purposes is a key and often difficult task for tax administrators.

From the point of view of taxation of athletes' income, a situation may arise where it is not possible to base the determination of the tax residency of an athlete solely on the criteria laid down by the Income Tax Act, but it is necessary to apply to a specific case the provisions of double taxation treaties which, as international treaties, take precedence over the czech law.. Therefore, this paper deals with the issue of determining tax residency, but also tries to identify the nature and significance of the benefits and risks associated with changing tax residency, because it is athletes who are taxpayer participants who often deal with the question of how to move through tax residency to reduce the amount of their tax obligations.

Therefore, this paper also addresses the potential risks associated with moving domicile and tries to find answers to the question of whether the tax benefits and potential benefits outweigh the possible risks.