The Tax Treatment of Non-Resident Sportsmen Image Rights: An Ambulatory Interpretation of the Spain-Netherlands Tax Treaty

In this article the author focuses on the Spanish taxation of image rights related to international sportsmen, the complexity of which has led to inconsistent judicial and tax authority decisions regarding interpretation, particularly with regard to the characterization of income from such rights. The article highlights a recent Supreme Court decision that, although it clarifies the taxation of image rights, may lead to further interpretation problems in other cases.