How are image rights valued in professional sport?

How image rights are valued in professional sport, and what the April 2028 tax changes mean for athletes, clubs, agents and image rights companies.

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For professional athletes, commercial value often extends beyond salaries, prize money and appearance fees. Sponsorships, endorsements, licensing arrangements and other commercial activities can generate significant income throughout a career and beyond.

Valuing image rights, however, is rarely straightforward. Unlike physical assets or trading businesses, image rights derive their value from an individual’s ability to generate future commercial income through their profile, reputation and marketability. As a result, valuations require careful consideration of both commercial opportunity and the risks that may affect future earnings.

In this guide, we explore the factors that drive image rights value, the methodologies commonly used to assess it, and the key risks and considerations that influence valuation outcomes in professional sport. We also explain what the image rights changes confirmed at the Autumn Budget on 28 October 2026, now due to take effect from 6 April 2028, mean for image rights companies and for how valuations are prepared.

What are image rights?

Image rights broadly represent the commercial value attached to an individual’s name, likeness, reputation and wider personal brand.

In the UK, image rights are not governed by a single statutory regime. Instead, protection is typically derived from a combination of contractual arrangements, trademark rights, copyright protections and the law of passing off. This makes image rights inherently fact-specific and means their value is closely linked to how they are identified, documented and commercially exploited in practice.

What creates value in an athlete’s image rights?

Existing commercial agreements

Contracted endorsement and sponsorship income often provides the strongest evidence of value. Existing agreements demonstrate that third parties are willing to pay for access to an athlete’s profile and provide a measurable starting point for forecasting future earnings.

The nature of the agreements is also important. Long-term arrangements with established counterparties generally provide greater certainty than short-term or highly contingent arrangements.

Sporting profile and performance

Commercial value is often closely linked to sporting success. Performance, visibility, achievements and participation at the highest level can significantly influence an athlete’s attractiveness to sponsors and commercial partners.

However, sporting success alone does not determine value. Two athletes competing at the same level may have very different commercial profiles depending on their public appeal and marketability.

Media exposure and commercial platform

Image rights value is influenced by the wider commercial ecosystem in which an athlete operates.

Media rights, sponsorship revenues, international broadcasting reach and the profile of a particular sport all affect visibility and commercial opportunity. A move between clubs, leagues or competitions may therefore influence value not only because of sporting considerations, but because the athlete is being placed on a different commercial platform.

Personal brand strength

Audience engagement, public profile and sponsor appeal are increasingly important drivers of value.

An athlete with a strong personal brand may generate commercial opportunities that extend beyond sporting performance alone. Reputation, authenticity and alignment with commercial partners can all contribute to long-term marketability.

How are image rights commonly valued?

In practice, image rights are most commonly valued using a discounted cash flow methodology.

The underlying principle is relatively straightforward: the value of the rights is linked to the future commercial income they are expected to generate.

The valuation process therefore involves:

Identifying relevant commercial income streams
Assessing commercially supportable future income expectations
Assessing the risks associated with those forecasts
Discounting future cash flows to a present value

While the concept is simple, the quality of the valuation depends heavily on the reliability of the assumptions used.

Unlike many business valuations, image rights forecasts are often limited to a defined period reflecting the athlete’s expected commercial relevance. A terminal value may not always be appropriate unless there is persuasive evidence of enduring post-career income.

Download our practical guide to protecting and commercialising image rights

Whether you’re a professional athlete, sports personality, agent or adviser, understanding the commercial value of image rights is essential. This guide explains how image rights work, when an independent valuation may be required and the key considerations when establishing image rights companies, negotiating commercial agreements or responding to HMRC enquiries.

Inside the guide you’ll discover:

What image rights are and why they matter
When an image rights valuation may be needed
How image rights companies are typically structured
The factors that influence the value of image rights
Common commercial scenarios and practical examples
How robust valuations can support commercial decisions and withstand HMRC scrutiny

Download your free copy of our guide here.

Forecasting future commercial income

Forecasting is often one of the most important and judgemental aspects of the valuation process.

Contracted income

The duration of contracts, renewal provisions, performance conditions and the quality of counterparties all influence the degree of certainty attached to future earnings.

Expected renewals

Valuation analysis frequently requires consideration of whether existing arrangements are likely to continue beyond their current term.

This requires careful assessment of the athlete’s profile, historical relationships and the commercial rationale for renewal.

Future opportunities

Athletes may have realistic prospects of securing additional sponsorship or endorsement arrangements in the future.

However, distinguishing between probable and highly speculative deal opportunities is important. Robust valuations require a clear evidential basis for any forecast growth. Moreover, forecasts are usually time-limited to reflect the relatively short window of peak sporting and commercial relevance, and a terminal value is often excluded unless there is compelling evidence of enduring post-career income.

Understanding risk

Image rights are unusual because many of the key risks relate directly to the individual rather than to a business or asset base.

Injury risk

A serious injury may reduce visibility, playing opportunities and commercial attractiveness, either temporarily or permanently.

For athletes whose profile is closely linked to current performance, injury can have a significant effect on future commercial income.

Performance risk

Loss of form, reduced selection or declining competitive performance may affect both audience engagement and sponsor interest.

This can be particularly relevant where commercial opportunities depend on continued participation at the highest level.

Reputational risk

Image rights are highly sensitive to reputation.

Adverse publicity, disciplinary matters, off-field behaviour or changing public sentiment can affect endorsement income quickly and disproportionately.

Commercial risk

Forecasts may also be affected by uncertainty around sponsorship renewals, future endorsement opportunities and changing market conditions.

The challenge for valuers is to ensure these risks are appropriately reflected without double counting them elsewhere in the analysis.

Discount rates and risk adjustments

Whilst the selection of an appropriate discount rate is an important component of any image rights valuation, risk is not captured through the discount rate alone.

In many cases, specific risks may be better reflected through:

More conservative cash flow assumptions
Shorter forecast periods
Scenario analysis
Probability weighting of future outcomes

An experienced valuation approach will consider whether uncertainty is most appropriately reflected within the cash flows themselves or through the discount rate applied to those cash flows.

How does career stage of an athlete influence value?

Image rights value is not static and will often evolve throughout an athlete’s career. While emerging athletes may have substantial future potential, established athletes often benefit from proven commercial appeal and existing income streams. In some cases, commercial value may continue beyond retirement through media, ambassadorial and other brand-related activities.

Valuations should therefore be tailored to the individual circumstances of the athlete concerned and anchored in current circumstances, with any forward-looking considerations limited to those expectations that are reasonably supportable and reflected in market pricing at the valuation date.

Can image rights valuations come under HMRC scrutiny?

HMRC may examine whether image rights arrangements reflect genuine commercial value and are supported by appropriate evidence.

In such circumstances, a valuation must do more than produce a numerical conclusion. It must be supported by a clear methodology, reasonable assumptions and a robust evidence base capable of withstanding scrutiny.

This is particularly important where image rights have been transferred into a corporate vehicle and the valuation forms part of the supporting documentation for the arrangement.

From 6 April 2028, that scrutiny is expected to move onto a statutory footing, as image rights payments related to an employment will be treated as employment income. HMRC’s existing guidance already looks for a commercial justification for separating payment for an employee’s duties from payment for the use of their image (HMRC Employment Income Manual, EIM00738), and the evidence supporting that separation will increasingly decide how a payment is taxed.

What is an Image Rights Company (IRC)?

In the UK, athletes typically own their image rights and often establish an Image Rights Company (IRC) where they assign their image rights to the company. This company, where the athlete is usually the director and shareholder, serves as a vehicle to manage and monetise their personal brand. Through an IRC, athletes can license their image for commercial use, separate from their employment income.

Benefits of an IRC include:

1. Post-career income

A professional athlete’s career is often short-lived. An IRC provides a structure for continued income through licensing and endorsements even after retirement.

2. Tax treatment

Under the current rules, a club’s payment for the genuine commercial use of a player’s image can be made to the IRC and taxed as company profits at Corporation Tax rates, rather than as employment income subject to Income Tax at up to 45% and National Insurance Contributions (NICs) for both the player and the club.

From 6 April 2028, that position is due to change, as image rights payments related to an employment are expected to be treated as taxable employment income and subject to Income Tax and NICs (Budget 2026: overview of tax legislation and rates), and paying them to an IRC is unlikely to alter that treatment. The tax advantage of an IRC will then rest on income that is genuinely independent of the athlete’s employment, such as personal sponsorship and endorsement agreements with third parties, which makes the evidence supporting that separation more important than the structure itself.

When considering succession and estate planning, an IRC can be structured to allow for smoother succession planning. Shares in the company can be transferred to family members or held in trust, making it easier to manage the athlete’s legacy and future income streams.

For athletes with international appeal, an IRC can also facilitate cross-border licensing and commercial opportunities.

3. Asset protection

In separating personal and commercial assets through an IRC, an athlete’s wealth is better protected should the company face any legal or financial issues.

How will the April 2028 image rights changes affect valuations?

The Budget on 28 October 2026 confirmed that the Government will legislate in Finance Bill 2026-27 to treat image rights payments related to an employment as taxable employment income, with the change now taking effect from 6 April 2028 rather than April 2027 as announced at Budget 2025. As the legislation has not yet been enacted, the detail of where the line falls between employment-related and independent income may still change.

Bryn Anderson, Partner at Price Bailey, comments:

The Government’s image rights reforms could materially reshape the economics of player remuneration in UK football. From April 2028, image-rights payments connected with a player’s employment are expected to be treated as employment income, bringing PAYE and NIC costs into arrangements that have traditionally sat outside salary. For clubs, this could increase employment costs, affect budgeting and cash flow, and lead to a rethink of existing contracts and future remuneration packages. Importantly, however, the reforms do not remove the underlying commercial value of a player’s image. Instead, the focus is likely to shift towards identifying and evidencing genuine standalone commercial value, particularly through independent sponsorships and endorsements, making the distinction between employment-related remuneration and genuine commercial exploitation increasingly important from a tax, accounting and valuation perspective.”

For a valuation, the reform does not reduce what an athlete’s image is worth commercially, but it does change which income can be attributed to the image rights and on what basis. Club payments connected with the athlete’s employment will need to be separated from income earned through independent sponsorships, endorsements and licensing, and forecasts for that independent income will need the evidential basis described earlier in this guide: signed third-party agreements, a record of renewals and a commercial profile that stands apart from the club.

Clubs, athletes and agents can use the additional year to identify which existing income streams are likely to fall within the new rules, model the effect on net pay and employment costs, and check whether any existing valuation would still support the arrangement once the rules apply. Contracts agreed now that run beyond April 2028 should be drafted with the new treatment in mind.

Closing thoughts

Image rights can represent one of the most valuable commercial assets available to a professional athlete.

A robust valuation requires careful consideration of future income streams, commercial opportunities, contractual evidence and the unique risks associated with professional sport. It also requires an understanding of how valuation conclusions may ultimately be used, whether in structuring exercises, commercial arrangements, HMRC enquiries or contentious matters.

As image rights continue to play an increasingly important role in professional sport, and as the April 2028 changes draw a firmer line between employment income and genuine commercial exploitation, the ability to produce clear, evidence-based and commercially grounded valuations will matter more for athletes, clubs, advisers and other stakeholders in this market.

How can Price Bailey help?

Our Valuation experts at Price Bailey have over 20 years of experience in image rights across the UK and internationally. We provide deep technical expertise across valuation methodologies to deliver grounded advice that withstands regulatory scrutiny.

Our dedicated sport industry specialists also understand the complexities of image rights in the sports industry. We offer tailored advice on:

Structuring image rights arrangements
Setting up and managing IRC
Ensuring tax compliance and maximising tax efficiency
Reviewing existing arrangements ahead of the April 2028 changes
Planning for long-term financial sustainability
Dealing with HMRC enquiries

For a free initial scoping call, you can contact our Valuation team using the form below.

We always recommend that you seek advice from a suitably qualified adviser before taking any action. The information on this page is intended as a general guide only. While we work to keep our content accurate and up to date, we cannot guarantee that it reflects the position at the time you are reading it. No responsibility for loss occasioned by any person acting or refraining from action as a result of this material can be accepted by the authors or the firm. For more information on our editorial process, click here.

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