The UK’s decision to drag image rights into the full income tax net from April 2027 looks like a small line in the Budget, but it has the potential to reshape how elite athletes are paid, and how Premier League clubs manage their salary bills.

What appears on paper as a modest £40m‑a‑year revenue measure could end up rewriting contract structures, pushing up gross salaries and tightening financial screws on clubs already living close to their regulatory limits.

The change is bigger than just football, it is framed as a reform to image rights for “sportspersons and other public‑facing individuals”, but football is where the impact and scrutiny will be most visible. That is where image rights structures are most embedded, where contracts are most complex, and where political attention on high earners is at its sharpest.

The holiday season is here and TaylorMade is making it ridiculously easy to score something everyone on your list will actually love.

The Qi35 lineup is built for players who want more speed, more forgiveness, and a whole lot more fun on the course. Right now you can save $100 on Qi35 drivers and $50 on Qi35 fairway woods and rescue clubs.

Whether you’re upgrading your own bag or surprising the golfer in your life, this is the kind of gift that pays off round after round.

Shop Qi35 Now

For the last two decades, the standard model at the top of English football has been simple on the surface: salary plus image rights. A player’s core wage is taxed under PAYE, while a separate agreement allows the club (and sometimes sponsors) to pay the player’s personal image rights company for the commercial use of their name, likeness and brand. That company is taxed at the corporate rate, around 25%, instead of at the 40–45% top income tax band and National Insurance that applies to salaries, and historically has sat outside PAYE where the commercial activity can be justified.

At the very top end, that structure is not marginal. Image rights can account for up to around 15–20% of a star’s total earnings, with the company sometimes booking millions a year in revenue. Multiply that by a squad of high‑earning players and it becomes a meaningful lever for managing both club payroll costs and players’ effective tax rates, all within a framework that has been accepted, if heavily scrutinised, since the early Arsenal “Sports Club” case around Dennis Bergkamp and David Platt.

The Autumn 2025 Budget proposes that from 6 April 2027 “all image rights payments related to an employment” will be treated as taxable employment income. In practice, that means club‑linked image rights payments will no longer enjoy PAYE and NIC exclusions: they will be pulled into the same 45% top income tax rate and employer and employee NIC regime as salaries. The measure sits inside a wider tax‑administration and compliance package expected to raise around £2.3bn, with this specific image‑rights change forecast to bring in roughly £40m a year, small in fiscal terms, but highly concentrated on a narrow group of top earners.

Where there is a clear employment link, a club contract for rights, or potentially a shared sponsor tied to both club and player, the traditional neat line between “salary contract” and “image rights contract” effectively collapses for tax purposes. Genuine third‑party sponsorships that are commercially independent of the club should still fall outside employment income, but the wording leaves questions around grey areas and how aggressively the rules will be interpreted.

Removing the image‑rights arbitrage raises the true cost of preserving the same net package for players. Today, shifting 10–20% of a superstar’s remuneration into a 25%‑taxed company instead of full payroll rates can save meaningful money when scaled across an entire squad. From 2027, that slice will attract the 45% band plus NIC if linked to employment, pushing up the effective “all‑in” cost of contracts unless clubs reduce packages or pass more tax risk back to players. This matters in a league where many deals are negotiated on a net‑pay basis. Clubs often shoulder the tax risk and manage liabilities directly, meaning an increase in headline tax rates on image‑rights income translates directly into higher salary bills and tighter headroom under profitability and sustainability rules. Some foreign players already have clauses requiring clubs to cover major tax changes, which could amplify the pressure on club P&Ls just as new financial regulations and quasi‑salary‑cap mechanisms come into force.

From the player’s perspective, the maths is blunt: income that has effectively been taxed at 25% will move towards 45% plus NIC where it is connected to club employment. That hits hardest for global names whose image rights companies are already booking multi‑million‑pound revenues annually. Agents are unlikely to accept a straight reduction in net take‑home; the expectation is that they will push for higher gross salaries, richer bonuses or specific change‑of‑law protections in new deals, particularly for contracts that run beyond the 2027/28 tax year. This change also lands alongside other tweaks to the way tax is collected from high earners, including plans to payroll more benefits from April 2027 and to bring more Self Assessment liabilities into PAYE from 2029.

Together, these moves concentrate more of a player’s tax burden into the monthly pay packet, compressing perceived cash flow just as the image‑rights advantage is taken away.

From the government’s side, the headline numbers may be modest, but the symbolism is powerful: tackling what is seen as aggressive tax structuring in a high‑profile sector, and signalling that “the use of image rights to avoid employment income” is no longer acceptable.

For the Premier League, this is another turn of the screw in an already tightening landscape of financial regulation, cost control and political scrutiny.

For clubs, advisors and investors, the message is clear. Over the next 18–24 months, remuneration models that have been standard for a generation will need to be unpicked and rebuilt, not just in football, but across elite sport and other public‑facing industries where image drives value. Football will simply be the first place everyone sees the impact.