Image rights can be a major source of income for sports professionals and others with high public profiles.  The idea is that the individual has two different sources of income - for example, a "celebrity" sports professional will be paid for playing sport and also for allowing his or her "brand" to be used.  

If the person in question is not UK domiciled, there is a large incentive to park image rights offshore so that income received is not taxed in the UK.   

This is a particular issue in relation to footballers, who are highly mobile (hopefully on the pitch as well as off) between countries.  According to the House of Commons' Public Accounts Committee: "HMRC told us that 43 footballers, 8 agents and 12 football clubs are currently under inquiry around the issue of image rights."  

This is an area that is within HMRC's radar and individuals who are pushing the limits by attributing large amounts of income to offshore image rights and leaving little income taxable in the UK for carrying out their "day job", may expect a call from HMRC.  

It should be stressed that, as long as the split in value is reasonable, what is being done is supported by case law and is not illegal.  However, that does not mean that the PAC and HMRC are happy with the situation and pressure may be applied to Ministers to change the law.  Possibly this March's Budget is a little early to see new legislation but, especially with the ongoing squeeze on public finances, it is unlikely that the current position will continue indefinitely.