Are sports image rights assets? A legal, economic and tax perspective

This paper highlights the factors to consider in entering into sports agreements including the tax treatment applied to image rights and the recent update and commentary of the Inland Revenue (HRMC) to their capital gains tax manual on the taxation of image rights. The commentary of HRMC on image rights is yet another indication that, although traditional common law remedies will evolve further in the light of the growing commercialisation of image rights, a formal legislative or jurisprudential recognition of personality rights remains unlikely in the near future in the UK