It’s common for individuals to establish legal entities to exploit their image rights. But how is the value arising from this assignment agreement taxed?
Until then, the Administrative Council of Tax Appeals (CARF) emanated the understanding that the taxation of the assignment of image rights could not be carried out through a legal entity, preventing taxation on the individual, given the personal nature of the image assignment contract.
However, in 2023, rulings issued by CARF Judges were published, containing the understanding that there is no irregularity in the assignment of image rights for exploitation through a legal entity, given the lack of an express prohibition in the legal system, which rekindles a flame of hope for taxpayers.
