Karolina Tetlak

Taxation of Athletes Participating in the Olympic Games: Under Article 17 of the Oecd Model Tax Convention Karolina Tetlak

The tax treatment of income earned by sportsmen participating in the Olympic Games is governed by domestic law and double tax treaties based on the OECD Model Tax Convention. Article 17 of the OECD Model provides an exceptional allocation rule that gives the Olympic host state an unlimited right to tax income earned by athletes in the territory of that state. This book examines the (in)applicability of Article 17, with its source-based taxation, to income earned by sportsmen from their participation in the Olympics. It discusses the profits that Olympians may derive from the Games and the tax treatment of such profits under Article 17 of the OECD Model from the perspective of international tax policy. This analysis should help shed some light on tax problems that arise in the context of the Olympic Games and call into doubt the appropriateness of the treatment model based on unlimited source taxation of athletes proposed by Article 17. The book will be especially useful to sports professionals, sports organizations, tax experts and tax administrations in countries considering hosting the Olympics.