TC09624 - [2025] UKFTT 01065 (TC)
First-tier Tribunal (Tax Chamber)

TC09624 - [2025] UKFTT 01065 (TC)

Fecha: 23-May-2025

Slazengers

Slazengers

18.

On 25 October 2010, the Appellant entered into a sponsorship agreement with Slazengers (“the Slazengers Agreement”), whereby Slazengers provided him with cricketing equipment, and where he agreed to promote Slazengers’ brand and make use of the equipment provided. In consideration for the agreement, Slazengers would pay the sums earned by the Appellant to International Sports Management Limited (“ISM”) (“the Authorised Agent”). The specified contract period was 1 January 2011 and 31 December 2013. The Slazengers Agreement provided for “Sponsorship Payments”, which were defined as:

such amounts payable to the Company on the occurrence of such events as specified in Schedule 1.

19.

‘Schedule 1’ provides that:

“1.1

Subject to paragraphs 1.2 and 1.3, the Company shall pay to the Player a retainer per Contract Year (“Retainer”) of £75,000.

1.2

If the player achieves a career aggregate of 5,000 Test runs of 5,000 One Day International (“ODI”) in the first Contract Year, the Retainer for Contract Years two and three shall be increased to £80,000.

20.

Additional performance-related payments were also set out in Schedule 1.

21.

‘Clause 3.1’ and ‘Clause 3.2’ dealt with “payment and consideration”.

22.

‘Clause 4.1’ provided for Sponsorship Payments on the basis that the Appellant undertook to wear, use, carry and promote bats and goods whenever training.

23.

‘Clause 11’ dealt with the designation of the “Authorised Agent” for the purposes of invoicing and collecting amounts due in connection with the Agreement.