For most professional athletes, commercial income — sponsorships, endorsements, appearance fees, licensing of name, image and likeness — is a larger long-term wealth contributor than playing income. Yet the vast majority of UAE club contracts I review bundle image rights directly into employment compensation, meaning commercial revenue is treated as employment income in the athlete's home country and taxed at top marginal rates.

The properly structured alternative — separating image rights into an offshore vehicle that licenses use back to the club and to third parties — is well-established and one of the highest-ROI commercial-legal decisions an athlete can make.

What image rights actually means.

Image rights are the commercial rights of an individual in the use of their name, likeness, signature, personal brand, voice and persona — for sponsorships, endorsements, merchandising, advertising, video games, NFTs, and any other commercial use of the individual's identity. They are conceptually distinct from playing services, which is the athletic performance the athlete provides to their club.

The distinction matters because the two streams have entirely different tax treatments. Bundled, image-rights revenue is taxed at the athlete's home-country marginal rate. Separated, it can be earned at a corporate level in a tax-favoured jurisdiction and distributed tax-efficiently.

The standard structure.

The mainstream architecture across world football, F1, tennis, golf and basketball involves:

  1. An image-rights company (IRC), typically incorporated in BVI, Cayman, Jersey, Guernsey, or one of the UAE common-law jurisdictions (ADGM, DIFC).
  2. An assignment of image rights from the athlete to the IRC, by deed of assignment with fair-value consideration.
  3. A licensing agreement under which the IRC licenses use of the image to the athlete's club for club-driven commercial activity.
  4. Direct sponsorship contracts between the IRC and third-party brands.
  5. Compensation to the athlete from the IRC as salary, director fees, dividends or loan, optimised against residency position.

Why most UAE club contracts get this wrong.

  • Bundles image rights into the headline salary. The contract refers to 'salary inclusive of image rights'. Commercial revenue is treated as employment income throughout the engagement.
  • Assigns image rights to the club for the contract duration. The club is granted broad, exclusive use including for non-club commercial uses without proportionate compensation.
  • Provides no carve-out for third-party endorsements. The athlete cannot enter direct deals or must split revenue without commercial basis.
The athletes who properly separate image rights at the start of their UAE engagement typically retain 25-40% more of their commercial income over the contract period. The structuring pays for itself within the first sponsorship deal.

The home-country tax dimension.

The image-rights structure does not avoid tax. It positions the tax — typically at the corporate level, in a tax-favoured jurisdiction, with onward distribution managed against the athlete's residency position. The key levers are:

  • Athlete personal residency. Athletes with UAE tax residency are positioned very differently from those still resident in their home country. Anchoring UAE residency properly is a prerequisite.
  • IRC jurisdiction choice. Common-law jurisdictions with reliable banking and substance (ADGM, DIFC, BVI, Cayman, Jersey, Guernsey) carry different cost, substance and treaty implications.
  • Substance positioning. Post-BEPS, even offshore IRCs need defensible substance — local director representation, banking, decision-making.
  • UAE Corporate Tax integration. Where the IRC sits in the UAE, UAE Corporate Tax integration matters — particularly Free Zone Person 0% qualifying-income treatment.

What the IRC actually does day-to-day.

  • Negotiates sponsorship contracts in its own name.
  • Licenses image rights to the athlete's club on commercial terms.
  • Maintains bank accounts, accounting records, board minutes, audited financials where required.
  • Holds and manages registered trademarks for the athlete's personal brand.
  • Engages legal, accounting and marketing services.
  • Manages the athlete's NFT and digital-licensing portfolio.

The implementation timeline.

From engagement to operational IRC typically takes 8-14 weeks:

  • Weeks 1-2: Tax-residency review, jurisdictional choice, structuring memo.
  • Weeks 2-4: Incorporation, banking account opening, KYC.
  • Weeks 4-6: Image-rights assignment deed, valuation, licence agreement to club.
  • Weeks 6-10: Trademark registrations, sponsorship template, governance setup.
  • Weeks 10-14: First sponsorship engagements through the IRC.

When NOT to structure image rights.

  • Athletes with very low commercial revenue. Under USD 75,000 annual commercial income, structuring cost outweighs benefit.
  • Athletes whose home country has anti-IRC rules. Some jurisdictions (notably UK historically) have specific anti-image-rights legislation. Structure must be designed against actual residency.
  • Athletes nearing end-of-career with no post-playing commercial brand. The structure makes most sense for athletes whose brand value extends beyond playing.

Conclusion.

The bundled image-rights / employment compensation model that dominates UAE club contracts is the single most expensive default position for any athlete with meaningful commercial income. Properly structured separation through an IRC — combined with anchored UAE residency, defensible substance and a thoughtful jurisdictional choice — typically recovers 25-40% of commercial income over the contract period. Neo Legal works with athletes from contract-negotiation through to IRC implementation and ongoing maintenance.