A number of prominent Premier League footballers are reported to have taken advantage of the little-known provision to save millions of pounds in tax.
It is claimed more than 50 players are making a tax saving of 22 per cent by having a proportion of their salary paid through image rights companies, which are liable to corporation tax at 28 per cent rather than income tax at 50 per cent.
In some cases, it is claimed, players are paying as little as two per cent tax by taking money from the image rights companies as loans, which are classed as benefits in kind.
Payments for image rights can be made to people – often high-profile performers or sports personalities – whose physical appearance and name have a commercial value in their own right, such as when used on merchandise.
A Revenue and Customs spokesman said: "The taxation of image rights is a complex area."
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