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Comment: Elite rugby players show how mobility can win with cross-border tax issues, writes Sean Cockburn

It’s that time of year when weekend plans are structured around Six Nations rugby fixtures and every conversation starts with a dissection of the squad selection, tactical decisions and how Scotland can be so consistently inconsistent – illustrated perfectly by losing badly in Italy before an impressive win against England.

While this tournament gives us no shortage of talking points, very few of these relate to the financial reality facing the players themselves.

Elite rugby professionals show how location, mobility, and multiple income streams can collide with tax. A player’s earnings often span several sources, including club salaries, international match fees, structured win bonuses, and an increasing share of sponsorship and commercial partnerships.

Together, these elements create a complex tax landscape that mirrors the challenges faced by many high-earning professionals as they generate income both domestically and internationally.

Home turf divide

When considering tax, given the recent Calcutta Cup win at Murrayfield, it feels appropriate to consider the tax discrepancy between Scotland and the rest of the UK, since choosing which side of the Tweed to call home can have a measurable impact on take-home pay.

For the 2026/27 tax year, the higher-rate threshold in England remains at £50,270 with earnings above this point taxed at 40 per cent before rising to 45 per cent only once income exceeds £125,140.

Scotland, by way of contrast, reaches higher rates earlier, with the 42 per cent band beginning at £43,663, followed by a 45 per cent advanced rate kicking in at £75,001, and then the 48 per cent top rate applying to income above £125,140.

This steeper progression means high‑earning Scots move into elevated tax rates earlier and remain within them indefinitely. The higher tax burden is amplified further by the tapering of the Personal Allowance for those earning above £100,000 – a feature that applies UK wide – but when combined with the higher Scottish rates means some individuals face an effective marginal tax rate of 69.5 per cent once National Insurance is included. This is one of the highest marginal tax burdens anywhere in the Organisation for Economic Co-operation and Development (OECD) for this income range.

What does that look like in practice? On a £500,000 salary, a Scotland-based player would take home around £260,355 after tax and National Insurance versus £276,786 for the same earner living south of the Border. This is a difference of £16,431 that is attributable entirely to the cross-border tax divergence.For most people, decisions about where to live or base a family are driven by far more than tax alone, but a divergence of this size inevitably factors into decisions about where mobile professionals base themselves during peak earning years.

Looking further afield

The complexity can deepen further when professionals look abroad. Rugby players competing in the French top flight can earn well into six figures, with some tipping over the £1 million mark.

While these moves are often motivated by the desire for new experiences – much like the clients we advise who are exploring international opportunities – it is essential to understand the tax implications

.For example, high earners in France may be able to benefit from the “impatriate” regime, which can exempt 30 per cent of employment income, treated as an “impatriation bonus” (a top-up linked to the move to France and calculated by comparing the player’s salary with that of similar players who are not impatriates). Income received for games played outside of France can also be exempted with the combined exemption for the impatriation bonus and foreign activity income subject to an overall cap. In addition, 50 per cent of certain foreign-sourced passive income may be exempt. These benefits are available for eight years following a move to France. To qualify, a player must not have been a French tax resident for the previous five years, must establish tax residency upon arrival, must be recruited from abroad or transferred internationally with the impatriation bonus stated in the contract. In a short playing career, this type of tax regime can materially impact players’ financial outcomes.

Of course, you don’t need to be an elite athlete to face these hurdles. As remote consultancy work, international contracting and digital nomad lifestyles become increasingly common, more people are now generating incomes across multiple jurisdictions. Managing tax obligations in these circumstances can quickly become complex.

Notwithstanding any preferential tax regime, the central concern is often the risk of double taxation –being taxed on the same income in two different jurisdictions. While the UK’s extensive Double Tax Treaty network helps prevent double taxation, it does not guarantee you will be taxed at the lower of the two countries’ rates. It therefore essential for anyone earning abroad to understand the UK’s rules on tax residency. The UK taxes its residents on their worldwide income, so individuals who intend to work overseas need to ensure they meet the conditions to become non‑resident under the Statutory Residence Test. Without careful planning and adherence to the rules, someone assuming they are non‑resident could still be treated as UK‑resident for tax purposes.

Tactical planning

Back on home soil, high earners in Scotland still have several effective ways to manage the impact of higher tax bands. Pension contributions remain one of the most powerful tools for individuals to reduce their taxable earnings below key thresholds. For example, lowering net income to under £100,000 allows the personal allowance to be fully restored which could significantly reduce the overall tax burden.

Other salary-sacrifice arrangements for electric vehicles and other work-place benefits can also reduce taxable pay while delivering practical benefits. Tax‑efficient investment vehicles such as ISAs, although not reducing taxable salary, ensure that future investment returns and income are protected from tax, preserving long‑term wealth. For business owners or individuals with more flexible remuneration structures, reviewing the balance between salary, dividends and other forms of income can create further opportunities to optimise tax outcomes.

Like a rugby field, the tax landscape can be daunting with many pitfalls so having advisers in place who work together is the best way to develop a reliable plan.

Sean Cockburn is a private client tax partner at Forvis Mazars, specialising in international personal tax advice

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