An Analysis of Income Tax Implications from the Transfer of Soccer Players
Mr Siphamandla N Makhaya, Ms Lizanne Barnard

Abstract
Sports clubs often trade in players with each other through the player transfer system. Using the doctrinal research methodology, the study aims at providing an interpretative analysis of the income tax implications from transfer of professional soccer players between professional soccer clubs, based on the Income Tax Act 58 of 1962 (South Africa, 1962) (hereafter the Act)and the relevant case law. The research methodology used is the doctrinal research methodology which involved an extended review of literature. This article concludes whether the transfer fees arising from the transfer of soccer players should be included in the gross income or be subject to capital gains tax in determining the taxable income of the transferor club. In addition, the study also determines whether the transferee club can deduct the transfer fees in respect of the transfer fees paid in acquisition of player rights under s 11(a) of the Act.

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