Why Tax Residency Matters for International Athletes

For international athletes, e-sports players and online content creators, tax residency can be one of the most important elements of an international tax strategy.

Belgium may offer an attractive tax framework as certain foreign-source income can, subject to the applicable double tax treaty, benefit from an exemption mechanism rather than a foreign tax credit system. As a result, the overall tax burden may be lower than in some other jurisdictions.

However, these advantages are only available if Belgian tax residency can be properly established and supported with sufficient documentation. A thorough analysis of the individual’s circumstances is therefore essential before relying on Belgium as a strategic tax base.

How Is Tax Residency Determined in Belgium?

Tax residency forms the basis of the tax position of every internationally active athlete or e-athlete.

In Belgium, an individual is generally considered a Belgian tax resident if they have established their domicile or seat of wealth in Belgium. Belgian tax authorities do not only look at official registration, but also assess the actual facts and circumstances.

To support a Belgian tax residency position, useful documentation may include:

travel schedules;
tournament calendars;
flight records;
lease agreements;
utility bills;
bank statements;
proof of physical presence;
contractual documentation.

Can an Athlete Be Tax Resident in More Than One Country?

For internationally active athletes, it is not uncommon for multiple countries to claim tax residency at the same time.

To resolve these situations, double tax treaties generally contain so-called “tie-breaker rules”. These rules typically assess:

Where a permanent home is available;
Where the centre of vital interests is located;
Where the individual habitually resides;
Nationality;
Mutual agreement procedures between tax authorities if necessary.

These rules are particularly important for athletes and e-sports players who own or use several residences and spend substantial parts of the year abroad.

Can an Athlete Be Tax Resident in More Than One Country?

Tax Residency for E-Sports Players and Online Content Creators

Tax residency is becoming increasingly important for e-sports players, streamers and online performers.

These individuals may earn income from:

international tournaments;
prize money;
sponsorship agreements;
streaming revenue;
merchandising activities.

Because activities are often performed in different countries, it is important to maintain clear records demonstrating where activities were physically performed and whether foreign taxes were withheld.

Why Belgium Can Be Attractive for International Athletes

Many Belgian (e-)athletes earn income in several countries at the same time. This may include:

competition bonuses;
prize money;
participation fees;
sponsorship contracts;
streaming income;
merchandising income.

If this income is earned abroad, the foreign source country may levy taxes on that income. However, Belgian tax residents are generally taxable on their worldwide income, which may create a risk of double taxation. To address this, Belgium has concluded double tax treaties with many countries. Depending on the applicable treaty and the nature of the income, Belgium may provide relief from double taxation for certain foreign-source income.

Belgium can be particularly attractive in this respect. While many countries grant relief through a foreign tax credit mechanism, Belgium generally applies an exemption mechanism (with progression reserve), provided the conditions of the relevant double tax treaty are met.

This distinction is important: if athletes reside in a country that applies a tax credit, they will still pay at least the home country tax rate, regardless of the actual taxes due in the source country. Athletes residing in Belgium can in many occasions benefit from the (often lower) tax rates in the source states. As a result, the overall tax burden may be lower than in countries where foreign taxes are merely credited.

This illustrates why tax residency is not merely an administrative matter. For internationally active athletes and e-sports players, a proper analysis of each income stream is essential to fully benefit from the available treaty provisions and to avoid unnecessary double taxation

Example: International E-Sports Player Living in Belgium

Consider an e-sports player who is based in Belgium, participates in tournaments throughout Europe, receives sponsorship income from foreign brands and streams online content.

Before determining the Belgian tax treatment, it is necessary to assess:

where the player is tax resident;
where activities are physically performed;
how each income stream should be classified;
which double tax treaties apply.

The tax analysis may differ for sponsorship income, tournament winnings and streaming revenues.

B-Mobility can assist in reviewing these income streams and building a substantiated tax residency file containing travel schedules, tournament calendars, proof of presence and contractual documentation.

Key Takeaways for International Athletes

Anyone seeking to structure an international athletic career efficiently should ensure:

tax residency is clearly established and documented;
each income stream is analyzed separately;
contracts are negotiated with tax implications in mind;
supporting documentation is properly maintained;
taxes are allocated in line with treaty provisions and local legislation.

Belgium may offer an attractive framework and can serve as a strategic base for internationally active athletes and e-sports players.

Key Takeaways for International Athletes

How B-Mobility can help

B-Mobility, the international mobility solution of PKF BOFIDI, assists internationally active athletes and e-athletes with:

residency assessments;
tax treaty analysis;
income sourcing reviews;
cross-border tax compliance;
documentation of tax residency positions;
pre-move and post-move tax planning.

Need support determining your Belgian tax residency or reviewing your international income streams? Contact the B-Mobility team to discuss your situation and obtain tailored advice.