Kelly Stricklin-Coutinho

ARCHIVED: This Practice Note has been archived and is not maintained. This Practice Note discusses the interaction between EU law, in particular the fundamental freedom of establishment, and the UK’s old controlled foreign company (CFC) regime, in particular discussing the impact of the Cadbury Schweppes, Vodafone 2 and CFC and Dividend GLO cases. This Practice Note was produced in partnership with Kelly Stricklin-Coutinho.

ARCHIVED: This Practice Note has been archived and is not maintained. This Practice Note explains why EU law is relevant to the UK’s thin capitalisation and transfer pricing rules, in particular looking at the fundamental freedoms of establishment, movement of capital and movements of goods and services. It then goes on to explain the main elements in the first major EU case on thin capitalisation, Lankhorst-Hohorst, and the UK’s group litigation order on the questions that followed (the Thin Cap GLO). This Practice Note was produced in partnership with Kelly Stricklin-Coutinho.

This Practice Note provides a high-level overview of the key tax issues for the sports sector, including for clubs, players, athletes and agents. It covers employment taxes (income tax and National Insurance contributions (NICs)), IR35 and personal service companies, image rights, sponsorship, transfer and agents’ fees, corporation tax, VAT, cross-border issues such as double taxation and withholding tax for non-resident sportspeople, community amateur sports clubs (CASCs), property taxes and HMRC enquiries, and signposts to more detailed guidance on each area.IntroductionAs with any industry, tax law applies to the sports sector, largely in the way it usually applies, although there are some provisions specific to sport.A special feature of the sports sector is that there are a broad range of different types of entity within the sector, each of which may well be subject to tax, so an adviser considering the application of tax to a sport situation should consider widely what taxes might potentially apply. Multiple different taxes could be relevant to one situation or transaction.The

This Practice Note considers mediation in sports disputes, including its suitability, benefits and limitations. It explains how governing body rules, regulatory obligations and urgent deadlines affect the process. It outlines the frameworks offered by the Court of Arbitration for Sport, Sport Resolutions and FIFA. It also addresses mediation alongside disciplinary and arbitral proceedings, settlement approval, confidentiality, authority to settle and practical pitfalls. For guidance on mediation generally, see: Mediation—overview.Mediating sports disputes in fact means mediating a range of different types of issues that come up in sports. That could include commercial disputes, disputes within a local club, disputes as to the application of rules and disputes both within teams and between rival organisations. In this way, some of the usual features of commercial features may well be relevant, but in some disputes the options for resolutions may have to fit within the constraints of rules, or there may be no commercial element to the dispute at all.Key themes in sports disputesA number of key themes arise in sports disputes.One