Football Taxation - Players' Perspective: What are the Main Tax Issues relating to Termination Payments Paid to the Players?

Argentina

When players receive income from the transfer of federative rights between clubs (15% of the transfer value), both the tax administration (‘Federal Administration of Public Revenues’) and the courts consider such earnings to be part of the player’s salary.

A doctrinal debate has arisen regarding the termination clause, as it has a different legal nature from the transfer payment (which is compensatory in nature for the termination clause).

When the new hiring club assumes the payment of the player’s termination clause, from a tax perspective, it may be considered that the player has earned income. However, the payment of compensation to the club also generates a loss for the player which, when integrated into the taxable base, neutralizes the mentioned income.

In Argentina, case-law has held that the income earned by players from a club transfer is of a remunerative nature (fourth-category income), thus...

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