A helpful (and timely) development ahead of the 2026 FIFA World Cup

At its core, the approach is relatively straightforward:

Income received by a participating member association should be allocated based on where matches are played i.e. the number of matches in each country compared to the team’s total matches in the tournament.

Importantly, the same methodology is expected to flow through to downstream payments, including to players and independent contractors, with non-player employees more likely to follow a time-based allocation.

From a practical perspective, this is a sensible attempt to reduce double taxation risk in what is otherwise a highly complex, multi-jurisdictional event.

But there are a couple of important caveats:

• This is guidance, not a mandatory approach – alternative methods can still be used where they better reflect the facts
• Adopting the agreed method does not remove audit risk
• Consistency across all three jurisdictions will be key to managing disputes and accessing treaty relief where needed

For teams, players and support staff, this is a positive step, but it doesn’t remove the underlying complexity. Getting the allocation right (and documented) will still be critical, particularly given the scale of prize money and the number of stakeholders involved.

As ever with global sporting events, the tax position off the pitch remains just as challenging as what happens on it.

For more information visit the Government of Canada website here.

Would you like to know more?

If you would like to discuss this in more detail, please get in touch with your usual Blick Rothenberg contact or the Global Mobility team using the form below.