A soccer player’s promotional activities as a “brand ambassador” do not, on their own, constitute a commercial activity if the fees paid are intended solely to compensate for specific achievements and successes in the field of soccer. This was decided by the Düsseldorf Tax Court.
In a decision on 30 August 2017 the Supreme Tax Court held that where a third party provides his employees to a football club to serve as players, trainers or counsellors without receiving adequate consideration, the waiver of such compensation is to be considered as a taxable gift of the third party to the football club.
