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       #Post#: 61145--------------------------------------------------
       Re: HMRC to probe salary paid as "image rights"
   DIR By: D-Quins
       Date: March 9, 2021, 4:17 pm
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       The salary cap already includes image rights payments as defined
       in the regulations, SCHEDULE 2A, PART A, section 1.4.  Hence
       this is all about Tax.  I think the people impacted here will be
       the players as their tax will go up possibly.  The amount has
       already been declared to the cap manager so should be no issue
       there
       #Post#: 61150--------------------------------------------------
       Re: HMRC to probe salary paid as "image rights"
   DIR By: Bedeteddy
       Date: March 10, 2021, 1:56 am
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       Well there is always the possible implications of any tax or
       additional payments that the club may have to make, if HMRC deem
       image rights should have been paid via PAYE. NI employer
       contributions (which I believe is 13.8%) and any possible club
       pension contributions. (I'm not 100% sure of the pensions rugby
       players have or if NI and pensions fall under the salary cap but
       I assume they would).
       As the cap tends to be very tight even a finding of £100,000
       across all players, the club would need to find another £13,800
       which could push you over.
       #Post#: 61154--------------------------------------------------
       Re: HMRC to probe salary paid as "image rights"
   DIR By: poorfour
       Date: March 10, 2021, 4:22 am
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       I think it will only become a salary cap issue if it turns out
       that clubs have been artificially deflating salaries paid by the
       club and inflating image rights paid by "related" companies that
       the clubs deemed to be outside the cap. If HMRC finds that these
       payments have been inflated it will open up the question of
       whether it's been done to fiddle the cap - but I agree that it
       seems pretty unlikely that something will come of it.
       #Post#: 61163--------------------------------------------------
       Re: HMRC to probe salary paid as "image rights"
   DIR By: Somardino
       Date: March 10, 2021, 6:58 am
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       NI counts towards the Cap. However the determination that image
       rights payments from Employers count as salary for tax purposes
       was established during the first investigation into Rugby (and
       Cricket) in 2009, which was effectively HMRC’s test case before
       going after Football. It seems unlikely that the clubs have
       forgotten.
       #Post#: 61177--------------------------------------------------
       Re: HMRC to probe salary paid as "image rights"
   DIR By: FishQuin
       Date: March 10, 2021, 10:46 am
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       --- Quote from: Somardino link ---
       >
       > Poor fact checking for this article. Image rights payments
       from Clubs are considered part of ‘Permitted Salary’ under
       Schedule 2A of the Premiership Rugby Salary Cap Regulations and
       are already counted as part of the Cap.
       >
       --- End Quote ---
       If image rights are included in the salary cap, why were the
       Itoje image rights a problem during the salary cap investigation
       into Sarries? I’m not sayings you’re wrong, I would just like to
       understand.
       #Post#: 61178--------------------------------------------------
       Re: HMRC to probe salary paid as "image rights"
   DIR By: honkytonk
       Date: March 10, 2021, 10:49 am
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       Without knowing, my guess would be that they were quite large.
       If they were, thats a large chunk of cap
       #Post#: 61180--------------------------------------------------
       Re: HMRC to probe salary paid as "image rights"
   DIR By: Somardino
       Date: March 10, 2021, 12:08 pm
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       I understand the Itoje issue didn’t relate to the routine
       payments made for the use of a players image in club
       publications. It was an ‘investment’ made by Nigel Wray and two
       other Saracens directors for 30% of the value of Itoje image.
       Hence the over-valuation was viewed as an effort to give money
       (£800k) to a player outside of what was reported under the cap.
       #Post#: 61182--------------------------------------------------
       Re: HMRC to probe salary paid as "image rights"
   DIR By: ah306
       Date: March 10, 2021, 12:18 pm
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       As Somardino says, the salary cap investigation decided only
       half the investment was a scam on the basis that the valuation
       of the company was double what it should have been. This still
       seems suspect to me. I'd be very surprised if Wray or any of the
       other "investors" ever expected to see any kind of return on the
       money put in. More likely Maro Itoje Image Rights Ltd would
       slowly pay Maro Itoje the individual a salary and/or dividends
       in the most tax efficient way until the money runs out at which
       point the company is wound up and the investors say to
       themselves "Oh, what a pitty that investement didn't work out.
       Nevermind, that's business for you." and probably use the "loss"
       to offset tax on other sources of income.
       I'm not sure what changes to the salary cap regulations have
       been or are going to be made so amybe it's been done alrady but
       personally I think club owners investing in players image rights
       companies should be prohibited.
       #Post#: 61183--------------------------------------------------
       Re: HMRC to probe salary paid as "image rights"
   DIR By: poorfour
       Date: March 10, 2021, 12:41 pm
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       --- Quote from: FishQuin link ---
       >
       > If image rights are included in the salary cap, why were the
       Itoje image rights a problem during the salary cap investigation
       into Sarries? I’m not sayings you’re wrong, I would just like to
       understand.
       >
       --- End Quote ---
       Because they weren't image rights payments from Sarries... they
       were image rights payments from, IIRC, companies associated with
       Nigel Wray's family that Sarries claimed were nothing to do with
       them, guv.
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