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Università commerciale Luigi Bocconi

Facoltà di Giurisprudenza International and Comparative Taxation Course


This paper attempts to show a vision of the impact of the so-called “Beckham law” in the Spanish tax landscape, with a particular emphasis on the world of football. During its short time of life, this law allowed persons with earnings above € 600,000 to have a tax rate of 24% instead the 43% for all the residents. The reason of that was to attract to Spain great scientists, researchers, athletes, and finally all types of qualified professionals.

Antonio Pascual Díez 1703057 2012-2013

Table of contents
1. Introduction…………………………………………………………………….. 3 2. Article 17 OECD Model. Artists and Sportsmen……………………..………... 4 3. The Beckham Law, Real Decreto 687/2005……………………………………. 7 a. The modification of the article 93 law 35/2006…………………...…… 9 b. Reactions…………………………………………………………........ 10 4. Conclusion…………………………………………………………………...... 12 5. Bibliography ………………………………………………………………….. 14 6. Sitography …..……………………………….………………………………... 14


1. Introduction
I decided to do this paper on the Beckham Law because it has been a point of lot of discussions in Spain in the last years. The reason of that is why foreigners should have more benefits in taxation terms than the Spanish people. The idea of the Beckham Law was to attract people with talent giving them some fiscal privileges, but the success of it is not very clear. Some of the questions that people did are still without any answer, that’s why I understand that this is a very good example of an issue of international taxation: a different treatment because of nationality in terms of taxation inside the European Union deserves to be studied. Also the sports are an area that I like very much and especially the football so with this paper I have the possibility to relate my passion (football), my nationality (Spanish) and the subject (International Taxation). First of all, I’m going to study the international regulation of the artists and sportsmen given in the article 17 of the OECD Model and later on I will focus on the Spanish case, the laws that we will use are the Income Tax of the Physical Persons (“Impuesto sobre la Renta de las Personas Físicas) and the Real Decreto1 687/2005 and their amendments. In the case of the Beckham law it has been valid only during a period of six years and I think that would be interesting to know the effects that it had not only in the market of football but also in the attraction of talent. In 2010 when the law was amended many football clubs (mainly Real Madrid and Barcelona) threated to go on strike because they were going to pay much more for the salaries of their players (we will explain later why this happened). Of course, now that we are in a world extremely globalized, everything is connected so one action in Spain may have consequences in other countries; thus will be important to know the reactions and situations in some States. It’s also relevant to study the impact of this law in the European Union because is constantly looking for a higher harmonization in taxation. After doing this I would like to be able to answer if the introduction of this law helped Spain to attract more talent and if it’s the correct way to do it or if there are other ways that would help better to reach that goal.


Real Decreto: is a rule of law that emanating from the executive power (government) and needs the legislative approval in 30 days 3

2. Article 17 OECD Model. Artists and Sportsmen
1. Notwithstanding the provisions of Articles 7 and 15, income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as a sportsman, from his personal activities as such exercised in the other Contracting State, may be taxed in that other State. 2. Where income in respect of personal activities exercised by an entertainer or a sportsman in his capacity as such accrues not to the entertainer or sportsman himself but to another person, that income may, notwithstanding the provisions of Articles 7 and 15, be taxed in the Contracting State in which the activities of the entertainer or sportsman are exercised.

As we can see above, the article 17 of the OECD Model Tax Convention treats about the special regulation that artistes and sportsmen receive. Their performance income is often generated in many countries different than their country of residence, and this performance income is consequentially subject to special tax treatment. This article was introduced in the OECD Model of 1963 and was slightly changed while still having the same meaning until today2. The member countries of the OECD decided in the sixties to create this exceptional rule because they believed that without the article 17 this kind of people would escape from taxation under article 7. The State where the activities of a foreigner entertainer or sportsman are performed is allowed to tax the income derived from these activities. This regime differs from the one that should be applicable to the income of other types of activities, that’s why it makes important to establish and specify what is an entertainer or sportsman, what are the personal activities of an entertainer or sportsman as such and what are the sources and allocation rules for activities performed in various countries. In order to answer the previous questions, the Committee on Fiscal Affairs met in 2010, examined these and other questions related to the application of Article 17 3 and tried to give solutions. In some cases may be difficult to determine whether a particular item of income is derived by a person as an entertainer or sportsman from his personal activities as such, in the article we can see that the limits are not very clear. Let’s try then to define what an entertainer or a sportsman is. When we talk about an “entertainer or sportsman” includes anyone who acts as such in any type of event, the type of person becomes irrelevant, as the event where he participates. Therefore this article can be applied to an amateur who wins a monetary prize and also to a person who is not an actor but gets a fee for a single appearance in a television commercial or a movie. Hence we can say that there is not necessary to be a professional. As Almudí Cid and Serrano Antón4 said, the prize that for instance a


D. MOLENAAR, Taxation of International Performing Artistes. Doctoral Series, Academic Council, 2005. Page 33 3 Centre for Tax Policy And Administration. Discussion draft on the application of article 17 (Artistes and Sportsmen) of the OECD Model Tax Convention. 23 april 2010 to 31 july 2010. 4 J.M. ALMUDÍ CID and F. SERRANO ANTÓN. La fiscalidad internacional de los artistas y deportistas: especial referencia al artículo 17 del MC OCDE. Revista Jurídica del Deporte, num. 13. (2005) 4

viewer wins for a slam dunk contest before a basketball game would be part of the article 17. Regarding the activities the article doesn’t include only the appearance in an entertainment or sports event but also the advertising or interviews in the State related to his appearance and performance. The paragraph 1 imposes two conditions: the income has to be derived by a person “as an entertainer (…) or as a sportsman” and that it has to be derived “from his personal activities as such”. Even if the article tries to establish some limits, we have to pay attention to the case where the entertainer, gets some money derived from activities different from his person’s activities “as an entertainer” and may therefore not be covered by the article 17. In this manner it’s important to clarify in which circumstances income derived by an entertainer or sportsman can’t be related to the personal activities of the entertainer or sportsman “as such”. The main practical issue relates to the part of the remuneration of an entertainer or sportsman that relates to preparation and training, as opposed to the part which relates to actual performances. The inclusion of such preparation and training in the personal activities of entertainers and sportsmen, may create excessive administrative burdens for all parties involved especially in terms of classification of the taxable income at the level of the contracting state in which the preparation and training is done. Respectively, this may increase the compliance obligations of, for instance, football teams and players forming part of such teams commonly visiting other countries in the course of preparation and training before starting their competition season. Generally, preparation and training form part of their annual agreed remuneration hence the absence of additional contracts verifying the proportion of the income to be attributed to such trainings and preparations may prove to be rather challenging, time consuming and costly5. In order to solve these problems one of the proposals of the Committee on Fiscal Affairs was to change the word artists for entertainers and understands that preparation and training are normal activities of entertainers and sportsmen. Therefore the remuneration received in the State where he has been training and preparing would be covered by the article 17. The wording of article 17 leaves open the question of taxation of income from artistic and sporting activities in the state of residence. This means that is an open distributive rule which indicates that income “may” be taxed in the source state, omitting “only”. Thus, the primary taxation right is a decision of the state of source but the residence state also formally retains the taxing right. If the state of residence levies tax on such income under domestic law, it depends on Art. 23A or B of the OECD Model whether it must grant an exemption or allow credit for the tax paid to the source state6 Article 17 also causes problems, not only for the rich and famous artistes and sportsmen. The OECD allows gross taxation in the country of performance, then the taxable base there is very often much higher than the taxable base in the country of residence because the former does not allow deduction of expenses of earning the

Taxand. Comments on the Discussion Draft on the Application of Article 17 (Artistes and Sportsmen) of the OECD Model Tax Convention Issued on 23 April 2010 6 TETLAK, K. Tax Treatment of Team Performances under Art. 17 of the OECD Model 5

income, whereas the latter usually does. Therefore, this leads very often to excessive taxation, even when the withholding rate is lower than the tax rate in the residence country and double taxation is possible because of problems with the application of tax credits in the residence country. These two problems can only be prevented by considerable taxpayer compliance and tax administration cost7. But there are some other important issues regarding this article, is the case of the double taxation8. As we saw before, when artistes and sportsmen perform abroad they pay income tax in two countries. Not only in their residence country on their worldwide income, but also in the country of performance. And although tax treaties have been concluded, double (or excessive) taxation very often occurs and needs to be solved. Most countries levy a source tax on income earned by foreigners in the country with rates from 15% to 30%. The reasons are because countries want to eliminate the risk of tax avoidance and are not sure if the foreign artistes will mention the income in their tax return in their residence country. At his point, the existence of bilateral tax treaties (that had been signed by most of the countries) have a very important role dividing the taxing rights and aiming to eliminate the double taxation. Following the principles of the OECD, we can find two main principles:   Companies and self-employed persons pay the income tax in their residence country, unless they have a permanent establishment in the source country (Art. 7 OECD Model) Employees pay income tax in the country of work, unless when they remain employee in their country of residence, receive their salaries from that employer and work for less than 183 days in the other country. If so, only the residence country is allowed to tax the income (Art. 15 OECD Model)

These two principles follow the idea that the person has to contribute to a country’s state budget when he uses his infrastructure and facilities. The double taxation appears when the source country has the right to tax the income and the residence country sees also this income as a part of the world-wide income. To eliminate the double taxation issue the OECD recommended in his article 23 that the residence country should allow its artistes and sportsmen a tax credit for the foreign source tax. We can conclude that the role of the article 17 responds to an important need to treat the special taxation of these people because of their exceptional characteristics that we already mentioned. The regulation given by the OECD is not perfect (has been modified many times, and some limits are not very clear) but we can say that has met with the expectations and worked very well until our days.


M. TENORE, D. MOLENAR and R.VANN. Red Card Article 17?. Bulletin for International Taxation. March 2012. Page 127 8 D. MOLENAR. All Arts Tax Advisers. International Artistes and Sportsmen, Article 17 OECD Model, Problem of Double Taxation. (July 2010) 6

3. The “Beckham Law”, Real Decreto 687/2005
The Beckham Law is a Spanish tax law that was passed the 10th of June of 2005 and has been applied until 2010 to many foreign workers with special conditions. The law gained its nickname after football player David Beckham became one of the first foreigners to take advantage of it. The situation before the existence of this law was that any foreign worker remaining in Spain more than 183 days in a tax year was considerate as a “tax resident” which meant that was liable for Spanish taxes on his worldwide income, not only for his Spanish source income and assets and obviously he would be subjected to a flat 43% tax rate. With the introduction of the Beckham Law, an expat could apply to be taxed as a non-Spanish resident under the Spanish Non-Resident Income Tax rules; this meant they could only be taxed on the income they earned in Spain and not on the incomes that they may continue to earn elsewhere in the world. But the main novelty was that the expat would be subject to a flat 24% tax rate, rather than the taxation rates applicable to Spanish residents. Therefore the expat were paying of taxes the 24% of their salaries instead the 43% that were paying the Spanish residents. After being passed in 2004, this law was introduced in the article 93 of the Law 35/2006 of the 28th of November “del Impuesto sobre la Renta de las Personas Fisicas”9 (Income Tax of the Physical Persons). In this article we can find the pre-requisites to take advantage of this law: a) The individual cannot have been Spanish tax resident in the 10 years prior to moving to Spain. b) The reason behind the move to Spain was because an employment contract in Spain. c) The employment duties must be carried out in Spain, although it is possible to carry out some non-Spanish duties but these must be minimal. d) The employer must either be a Spanish resident company/entity or if not Spanish resident then the employer operates through a permanent establishment in Spain. e) The employment income received is not deemed to be exempt under the Spanish nonresident income tax law. And also, the application must be made within 6 months of starting the employment contract10. The intention of this law was to attract qualified personnel, scientists and high skilled professionals to incorporate them to Spanish companies11. It was also an attempt

LEY 35/2006, de 28 de noviembre, del Impuesto sobre la Renta de las Personas Físicas y de modificación parcial de las leyes de los Impuestos sobre Sociedades, sobre la Renta de no Residentes y sobre el Patrimonio 10 11 7

to induce foreign CEO’s to come to Spain and establish regional headquarters and residence in Spain. From this the Spanish government hoped the influx would lead to increased investment, higher qualified employees and economic interaction. Reducing taxes was seen as a way to compete with other countries and make possible an impulse in the Spanish economy. But this law was also exploited, hence its nickname, by the Spanish football clubs to recruit great players, given that in other European countries had to pay more taxes. We can appreciate that in 2005, in Germany the rate was 45%, in England were talking of an increase from 40% to 50%, in Italy was 43% (just to give the numbers of the countries where there are other powerful football leagues). In Spain, the fact that the foreigners could pay the 24% of taxes, served to have seen play in Spain: Beckham, Ronaldinho, Aguero, Ibrahimovic, Cristiano Ronaldo and many others. But also clubs with lower budgets took benefit of it and made La Liga the best football league in Europe (and possibly in the world). In fact, Cristiano Ronaldo went to Real Madrid in summer of 2009, curiously when were discussing in England to arise the tax rate from 40% to 50%, while in Spain under the Beckham law he would have to pay only the 24% thus the Spanish club could offer him a higher salary. A very empirical effect of the Beckham Law is that after its approval the fraction of foreign players in the Spanish league increased by 50 percent, while the Italian league — comparable in funding, number of foreign players and team performance before 2004 — stayed the same. So we can see that this exemption is applied to all foreign workers, although it is geared more toward wealthier expats i.e. middle and upper management rather than football players. But we have to consider that applying the Beckham treatment is not always such a great idea for all the foreigners12. The main reason is that although the non-resident tax rate stays at 24%, it doesn’t come with any personal allowances. A basic rate taxpayer or even one paying the highest rates (between 30% and 40%) can pay less taxes if he is taxed as a resident because the effect of personal allowances and deductions typical of the Spanish law. The effect is particularly pronounced in the first (and possibly the last) year of residence, when the taxpayer is only earning in Spain for several months because, as residents, they get a full year of allowances to offset against a part year of income. The second and slightly more subtle reason is that the worldwide income not taxed in Spain (probably) has not to be taxed somewhere. If the person has incomes besides that which has earned from employment in Spain (e.g. a sponsorship deal) and it’s taxed in Spain rather than another jurisdiction that might be a good thing rather than a bad thing. For example, the Spanish tax rate for interest and capital gains (21-27%) was the lowest among major European countries.

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a) The modification of the article 93 law 35/2006
The 3rd of November of 2009, the Budget’s Commission of the Spanish Congress amended the article 93 of the Law 35/2006 and it started to have effect from January 2010. From then on, all the foreign workers whose income were higher than € 600,000 would be taxed at 43% instead of the original 24%, thus the situation of the foreigners was equal to the rest of Spanish that exceed this amount. Thereby the Spanish Income Tax on Physical Persons was the same for both nationals and foreigners and consequently Spain lost the power of seduction on foreign workers It should be noted, nevertheless, that the law was not retroactive and this means that all foreigners who signed their contracts before that date (January 2010) would be still taxed at 24%. During the six years of its existence (2005 to 2010), many people from different fields, including football players who have employment relationships with football clubs, have applied the regime. The amendment has not though stopped important global banks from considering moving some of their London and elsewhere based teams to Spain to benefit from the impatriate regime, and to avoid the increase of tax rates there. The current trend was for financial institutions to consider moving some of their operations to Spain, with even some hedge funds also reportedly considering the option. But for my surprise it appears that only 2,000 people exercised the option to be taxed as non-resident; of which less than 10% had incomes above € 600,000 (43 were footballers and 17 senior executives)13. So it seems that the introduction of the Beckham Law had an impact lower than expected. According to María Sánchez-Biema14, manager of Human Resources of the consultant IMS Health “after six years seems clear that the goal has not been reached, as it has been very low the number of people who was under the conditions (especially high skills and ability to attract capital and investments) that should move to Spain ” said. He added that of course is a positive measure but not the best one in order to facilitate the arrival of talented people. As mentioned, under the amendment, employees expecting employment income of over €600,000 per year will no longer be able to apply the regime. The modification especially hits football players since many have in most cases their main income paid in the form of salary, to which the limit of €600,000 or above applies15. This explains for example why the Real Madrid only wanted to sell their player Kaká in summer of 2010 and not to give him in loan. If Kaká was loaned he would not be taxed in Spain, and then when was back in Spain he could not take benefit of the Beckham Law as before. Then the Real Madrid would have to pay much more for his


R. FALCÓN Y TELLA. Quincena Fiscal Aranzadi num. 21/2009 parte Editorial. Editorial Aranzadi, SA, Pamplona. (2009). 14 Correo Farmaceutico. 1st March 2010 15 S. VELASCO. Iberia Lawyer, January/February 2010. Page 30 9

salary, because almost all the contracts of players are signed in terms of net earnings so Kaká would pass to pay 24% to 43%.16 The main complaints of this reform came from the world of the Spanish football, where the big clubs disappointed with the measure; they predicted that this new tax situation would be a major obstacle to their future contracts17. I think is interesting to compare the different tax policies in 2009 in other countries similar to Spain in order to understand better the situation18:        Germany had a tax rate of 45% for earning above € 250,000 United Kingdom had a tax rate of 40% for earnings above € 49,370 France had a tax rate of 40% for earning above € 69,505 Italy had a tax rate of 43% for earning above € 75,000 The Netherlands had a tax rate of 52% for earning above € 54,776 The United States had a tax rate of 35% for earning above € 278,780 Spain had a tax rate of 43% for earnings above € 53,407

It was evident that the tax regime in Spain was very advantageous for persons with higher incomes thus it’s easy to understand that there were complaint from the other countries.

b) Reactions
From the Spanish Treasury the reform was applauded, they considerate it as necessary and very positive. Thus was suppressed a regime that allowed low taxation to millionaires incomes in the “Impuesto sobre la Renta de las Personas Físicas”. The increase from 24% to 43% for foreigners earning over €600,000 generated a big injection of money for the State. Regarding the world of Spanish football, the union of experts of the Ministry of Finance said in a statement that almost all the existing contracts clauses of players are signed in terms of net remuneration of these foreign athletes. This means that would be the clubs themselves who would have to pay the taxes, and therefore would be affected by the legal reform. The reactions after the reform was known were constants. The first of them came from the “Presidente de la Liga de Futbol Profesional” (President of the League of Professional Football of Spain), José Luis Astiazarán who said: “for the Spanish football will have very negative consequences and will cause irreparable harm because

16 17 E. SANTOS FRESCO. La Reforma de la “Ley Beckham” en el mundo del fútbol. Revista Internacional del Mundo Económico y del Derecho. (2011). Pagine 95-99 18 EL MUNDO, 8th November 2009 10

we will lose power in Europe, because the vast majority of good talents and players will choose other leagues instead of the Spanish”19. What José Luis Astiazarán was expressing were his concerns about the consequences that the reform would have in the Spanish clubs. They would have to assume the increase of the IRPF (“Impuesto sobre la Renta de las Personas Físicas”), so those clubs would lose a great power of contracting and at the same time lose he advantage they had in relation to other countries. This advantage was essentially that before the reform the Spanish clubs could offer higher wages since taxation was lower than other countries, thus clubs hired players with net salaries and taking over of the taxation of them, and therefore they needed less money to equalize the salaries of other countries. Also the main clubs of Spain, Futbol Club Barcelona and Real Madrid threatened to call a strike to avoid the modification of the Beckham Law, finally they got an agreement with the government and the Liga was not affected. But not all were complaints, the fans (the regular citizens who pay taxes) don’t understand how is possible that having a salary of millions of euros you get upset by a rise of tax rate. In fact the national radio station Cadena SER conducted a vote from its listenersa and from a 92% participation in the vote, 88% were in favour of the change of the law20. The effects of the Beckham law were also well known in other countries, and they were delighted with this new. Adriano Galliano, CEO of AC Milan said: “now seems that Spaniards and foreigners will be aligned, just as happens to foreign workers who come to Italy. Sure, I’m sorry for the Spanish clubs, I do not wish them any harm, but the tax now aligns with ours. I was hoping something a little different, a decrease of our taxes instead increasing theirs”. 21 It’s easy to suppose that the reaction of the rest of main European football club would be similar to the words of Mr. Galliani. They were being discriminated because the fiscal benefits of Spanish clubs to buy international players, it’s obvious the Beckham law was giving La Liga a competitive advantage.

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4. Conclusion
At this point I can say that without any doubt that although the controversial and complaints of several sectors, and in particularly as discussed for football, the reform of this legal principle has sought the equal tax payment for both nationals as foreign citizens, avoiding a discrimination in terms of contribute to the “state’s coffers”. However, in contrast, Spain lost a great potential of attraction for foreign qualified professionals, equalizing to almost all the states of the European Union. Nowadays we see all the weeks how newspaper and experts discuss about the necessity of a fiscal union in Europe. The existences of these kinds of laws are not beneficial for the needs of the Union, it’s necessary to move towards a higher harmonization rather than each State look after their own interests. We can see the problem that Ireland is causing because is applying very low taxes to the companies; I think this is not the proper way. The Spanish government justified the amendment by stating that high earning taxpayers cannot benefit from lower taxation, such as the one in the impatriate regime, considering Spain’s current economic crisis. However, I think that the government might not have analyzed enough the impact that this tax regime could have on the Spanish economy, particularly regarding many important economic sectors like life sciences, finance, and high-tech industries, as well as the activities directly or indirectly related to professional sports, such as publicity and communication agencies that move every year billions of euros. The Beckham law had positive effects but was not implemented in the best way possible (it’s not understandable why in 5 years only 2,000 people take advantage of this measure). I believe that the reduction of taxes has a great effect on the economies so the initiative of the Spanish government is correct but as I said before is important to reduce taxes or increase them all the countries as a whole and by this way we will also reduce discrimination. In the world of Spanish football, it’s clear that that the measure caused great economic losses for Spanish clubs and also the loss of attractiveness of the League for high skilled players, but they also had five years where they were having advantage from the rest of countries. Much to my chagrin I think that this measure discriminates the rest of countries and is not fair, especially for the clubs of other countries. In the past years with the reform already in effect, we have observed as the Spanish football market has been much more stopped in comparison with previous years, and one reason I think for this is, along the economic crisis, is the new tax regulation. The decrease of investment on football players in the season 2012-2013 has been of almost 62% when in other leagues as the German has increased in a 33% or the English a 20%. In absolute numbers the English League spent € 763 Million, followed the Italian (€ 426M), the German (€ 271M) and the French (€ 247M). La Liga, the Spanish League, “only” spent € 140 Million. This make us think the huge effect that taxation had in the Spanish football market.


My proposal then is that according that taxes should be reduced, the Beckham law is a good idea but it should not be applied to sportsman and athletes because of the discrimination that creates and in terms of sports all the clubs should have the same opportunities. In the case of scientists and high managers a reduction of taxes like this law has great effects in the economy and I think is always very important to keep and attract more talent in our countries. We constantly see in Spain how very skilled people leaves the country and goes to the United States, Germany, Asia looking for better opportunities, we have to change mentality and to make talent stay and come and a way to do it is through taxes.


5. Bibliography
J.M. ALMUDÍ CID and F. SERRANO ANTÓN. La fiscalidad internacional de los artistas y deportistas: especial referencia al artículo 17 del MC OCDE. Revista Jurídica del Deporte, num. 13. (2005) Articles of the Model Convention with respect to Taxes on Income and on Capital (OECD MODEL) A. CAÑERO VERA. Las rentas de artistas y deportistas en el marco de los Convenios de Doble Imposición. Jurisprudencia de los Tribunales españoles. Centre for Tax Policy And Administration. Discussion draft on the application of article 17 (Artistes and Sportsmen) of the OECD Model Tax Convention. 23 april 2010 to 31 july 2010Correo Farmaceutico. 1st March 2010 EL MUNDO, 8th November 2009 R. FALCÓN Y TELLA. Quincena Fiscal Aranzadi num. 21/2009 parte Editorial. Editorial Aranzadi, SA, Pamplona. (2009). LEY 35/2006, de 28 de noviembre, del Impuesto sobre la Renta de las Personas Físicas y de modificación parcial de las leyes de los Impuestos sobre Sociedades, sobre la Renta de no Residentes y sobre el Patrimonio D. MOLENAR. All Arts Tax Advisers. International Artistes and Sportsmen, Article 17 OECD Model, Problem of Double Taxation. (July 2010) D. MOLENAAR, Taxation of International Performing Artistes. Doctoral Series, Academic Council, (2005). Page 33 E. SANTOS FRESCO. La Reforma de la “Ley Beckham” en el mundo del fútbol. Revista Internacional del Mundo Económico y del Derecho. (2011). Pagine 95-99Taxand Comments on the Discussion Draft on the Application of Article 17 (Artistes and Sportsmen) of the OECD Model Tax Convention Issued on 23 April 2010 TETLAK, K. Tax Treatment of Team Performances under Art. 17 of the OECD Model M. TENORE, D. MOLENAR and R.VANN. Red Card Article 17?. Bulletin for International Taxation. March 2012. Page 127 S. VELASCO. Iberia Lawyer, January/February 2010. Page 30 Taxand. Comments on the Discussion Draft on the Application of Article 17 (Artistes and Sportsmen) of the OECD Model Tax Convention Issued on 23 April 2010

6. Sitography