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Thomas, Trevor Lloyd (2000) Legal aspects of international tax planning for sportspeople and entertainers: a critical examination from a UK perspective, with comparative analysis from a US perspective, of the degree to which offshore financial centres can provide effective tools for international tax planning for sportspeople and entertainers. Doctoral thesis, London Guildhall University.
No consolidated published work exists on the subject matter of this research. In 1983 a UK doctoral thesis stated that academic research into international tax law was in its early stages of development. Today, with the increasing globalisation of finance, the growth in offshore financial centres and the unprecedented mobility of capital and labour, the need for such continued research is compelling. This thesis seeks to increase the body of knowledge and analysis in that area international revenue law concerned with the use of offshore financial centres in international tax planning. The specific focus for the study is sportspeople and entertainers, arguably the most mobile business individuals in the world.
Offshore financial centres, by virtue of their low tax regimes and their provision of offshore companies, offshore trust and offshore limited partnerships, are widely considered to provide opportunities for tax avoidance for high earning and high net worth individuals in the developed world. The hypothesis tested in the thesis is whether offshore financial centres provide effective tools for international tax planning for sportspeople and entertainers from a UK perspective (with a comparative analysis from a US perspective).
Three themes weave themselves through this work. There is the theme of the taxation of sportspeople and entertainers, together with the relevant domestic and international anti-avoidance provisions. There is the theme of comparative tax law, between the UK and the US, and between Jersey (offshore UK) and the Cayman Islands (offshore US). The third theme involves an analysis of offshore financial centres themselves, their history and characteristics, and their corporate, trust and partnership vehicles.
This thesis has been researched and written up during the current debate within the OECD, the G7 countries and the EU on 'unfair tax competition'. The thesis consequently joins the debate on whether offshore financial centres by driving down the effective tax rate levied on income from mobile activities cause harm on a global scale.
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