International tax implications in esports

Leonid Shmatenko, Oleksandr Volkov and Rodolphe Ruffié-Farrugia

Chapter Chapter 9 in Esports Law and Practice, 2025, pp 174-192 from Edward Elgar Publishing

Abstract: This chapter reviews international tax implications in esports, summarizing core international tax law rules, particularly tax residence and income source concepts, and the application of double tax treatiesdouble tax treaties (DTTsDTTs) to avoid double taxation. It analyses income types and taxes, differentiating between tax implications for esports organizations and professional playersplayers. Additionally, the chapter examines the risks of foreign players being considered permanent establishments (PE) of esports organizations. It highlights that players providing services under agreements, rather than labour contracts, may be classified as agency or service PEs. This classification poses significant disadvantages for both organizations and players, altering DTTDTT application rules.

Date: 2025
ISBN: 9781803925998
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