The First-tier Tax Tribunal (FTT) has ruled that former professional cricketer Paul Collingwood is personally liable for almost GBP200,000 of income tax on image rights, where the related sponsorship deals went through his company PDC Rights and an authorised agent, International Sports Management Limited (Collingwood v HMRC, 2025 UKFTT 1065 TC). The FTT accepted HMRC’s argument that the charge on trade profits is on the person receiving or entitled to the profits. The impact could be wide, as many sports personalities have used such arrangements.
https://www.accountingweb.co.uk/tax/hmrc-policy/cricket-star-stumped-in-ps200k-image-rights-tax-row