Image rights for sports people and actors
It is said that the Government will "improve
integrity" in the tax system by ensuring from 1 July 2019,
high profile individuals are no longer able to take advantage of
lower tax rates by licencing their fame or image to another
entity.
The Budget papers go on to say that this is currently available.
What it does not note is that, the ATO had provided some "safe
harbour" to this concept by their release of draft Practical
Compliance Guideline PCG 2017/D11.
That draft PCG issued on 1 September 2017 referred to the
Supreme Court of Queensland decision in Brisbane Bears-Fitzroy
Football Club Ltd, which case dealt with Queensland payroll
tax, and that payments for "image rights" received by
footballers were wages.