UK Taxation of Foreign Performers: A Comprehensive Guide

Foreign performers – whether individuals or performance companies – are generally liable to pay UK tax on income from appearances or performances in the UK. To collect this tax, HMRC operates a withholding tax system for non-UK resident entertainers and sportspersons. In practice, the UK payer (agent, promoter, venue, etc.) must deduct a portion of the performer’s fee and pay it to HMRC if the performer’s UK earnings exceed a set threshold. This guide explains when UK tax applies (and when it doesn’t), how the withholding tax process works (including rates and refunds), how foreign performers can qualify for gross or reduced withholding, the required HMRC forms (FEU2, FEU8, etc.) with step-by-step instructions, and the VAT implications for both foreign performers and UK-based agents/promoters. All performance types – music tours, theatre shows, film productions, sports competitions, etc. – are covered under these rules.

Who Is Considered a Foreign Performer?

Foreign performers include any non-UK resident individuals or groups who perform or make an appearance in the UK. This spans a wide range of arts, entertainment, and sports. For example, entertainers covered by the rules include actors, dancers, models, musicians, singers, conductors, variety performers, and media personalities. Sportspeople are equally included – e.g. athletes, footballers, tennis players, cricketers, boxers, golfers, snooker players, cyclists, and so on. In short, if someone is coming from abroad to perform, compete, or participate in a public event in the UK (whether live or recorded, paid or prize-winning), they will typically fall under the “foreign entertainer or sportsperson” tax rules.

Importantly, the rules apply both to individuals and to performance companies or groups. Even if the performer is paid via a company or a group is paid as a single entity, UK withholding tax still applies. In fact, if a payment is made to a group or a foreign company that has both UK and non-UK members, HMRC instructs payers to deduct withholding tax from the entire payment. UK tax law even has provisions to look through certain entities: for example, payments made to a foreign entertainer’s personal service company are treated as personal income of the entertainer for tax purposes. The bottom line is that non-resident performers cannot avoid UK tax by routing income through companies or third parties – the Foreign Entertainers Unit (FEU) will ensure the performer’s UK-sourced earnings are taxed as required.

When Is UK Tax Due for Foreign Performers?

If a foreign performer has any earnings from performances or appearances in the UK, those earnings are in principle taxable in the UK. The UK has the right to tax income from performances on its soil, even if the performer is only in the country briefly. In practice, however, withholding tax is triggered only after a certain threshold. HMRC uses the UK personal allowance as a yardstick: if payments to the entertainer in a tax year exceed the personal income tax allowance (currently £12,570), then the payer must start withholding tax.

• Threshold (Personal Allowance): The personal allowance is the amount of income a UK resident can earn tax-free each year. Non-resident performers generally may not qualify for a personal allowance when filing taxes (unless a tax treaty or other criteria entitle them to it), but for withholding purposes HMRC effectively uses this threshold as a trigger. This means if the total fees for a performer’s UK engagements in a tax year do not exceed ~£12,570, no tax needs to be withheld at source. Conversely, once payments go above that threshold, UK tax is due on the income.
• Multiple Appearances: Be aware that the threshold applies to the total paid in the tax year, not per gig. If a performer has multiple UK appearances, the payer must monitor the cumulative total. HMRC advises that if you know in advance that multiple payments will together exceed the personal allowance, you should start deducting tax from the first payment onward, even if that first payment alone is under the threshold. In other words, you cannot simply pay out the first chunk tax-free and only start withholding later – if it’s foreseeable the performer will breach £12,570 in aggregate, begin withholding from the start. (For example, if a promoter agrees to pay an artist £8,000 for one show and £5,000 for a later show in the same tax year, totaling £13,000, then the promoter should deduct basic-rate tax from both payments, not just the second).
• Tax Treaties: Many countries have double taxation treaties with the UK. These treaties often have special articles for entertainers and athletes, typically allowing the UK to tax performance income even if the performer would otherwise not be taxed (so treaties generally don’t exempt this income, though some may set a minimum earnings threshold or conditions for exemption). If a treaty does provide an exemption or reduced rate (for instance, some treaties exempt performances below a certain earnings level or sponsored by a government), the performer must make a claim to HMRC to benefit from it. HMRC will not automatically know to ignore withholding tax without a claim. We’ll cover the process for claiming treaty benefits under “Gross Payment and Reduced Withholding” – but note that reduced or zero UK withholding can apply under a tax treaty only if HMRC approves the claim in advance.

When Is UK Tax Not Required? (Exemptions and Exceptions)

There are specific scenarios where you do not have to deduct withholding tax on payments to a foreign performer. According to HMRC’s rules, a UK payer should not withhold tax in the following cases:

• Payments below the annual threshold: If the total of all payments to the entertainer or sportsperson in the UK tax year does not exceed the personal tax allowance (about £12,570), no withholding is required. (For one-off or low-fee performances under the threshold, the payment can be made gross.)
• Cancellation fees: If you pay a foreign performer a fee for a cancelled show (i.e. compensation for not performing), that payment is exempt from withholding. It’s not considered earnings for a performance, so no tax at source is due on a genuine cancellation fee.
• Payments to a UK-taxed employee: If the performer is actually an employee on your UK payroll (paying tax via PAYE), then you do not also apply the non-resident withholding. This is a rare scenario – typically this applies if a non-resident is on a short-term employment contract and you’re taxing them through payroll already.
• Paying an HMRC-approved middleman: HMRC maintains a “middleman scheme” list of certain agents and organizations that are approved to handle tax for foreign performers. If the person or company you are paying is on the official middleman scheme list, you do not deduct withholding tax. Essentially, these approved intermediaries take on the responsibility for accounting for the tax. (For example, some large international talent agencies or sports promoters might be on this list – if you pay them rather than the artist directly, they will deal with HMRC.) Unless you see the payee on HMRC’s published middleman list, assume you must withhold tax.
• Royalties and copyright payments: Payments for intellectual property such as copyright fees, royalties, or advances on royalties are not subject to the foreign entertainers withholding tax. (These may be taxed under other rules – e.g. UK royalty withholding – but they are carved out of the performer WHT scheme.)
• Supporting services: Payments made to others for support services related to a performance are exempt. This includes fees for venue hire, equipment rental, ticketing services, security, catering, etc., paid to third parties. Only the performer’s performance fee or prize is taxed, not the cost of putting on the show.
• Certain modeling and behind-the-scenes work: Specifically, payments to models for still photographic shoots are exempt. Also, payments to catwalk/fashion models for events not open to the public (e.g. a private fashion show for industry, even if it’s filmed or streamed) are exempt. Additionally, payments made directly to film directors, camera operators, or technical crew are not subject to entertainer withholding, since these individuals are not performing as entertainers/sportspeople but providing technical services.
• Music recording sales: HMRC also clarifies that you should not deduct withholding tax from payments that represent the sale of audio recordings (music, etc.), as opposed to performance fees. For instance, if part of an artist’s contract includes a share of CD or digital download sales, or a non-returnable advance on future sales of recordings, those payments are treated separately (they’re essentially royalties from recordings) and are excluded from the performer withholding regime.
• Performances financed by public funds (treaty exemption): Some UK treaties such as the French one include a public-funding carve-out where the performance is “mainly supported by public funds” of one or both States (for example, where a government ministry, arts council, or other public body substantially funds the event). This is not an automatic UK domestic exemption—it applies only if the relevant treaty has this clause and you obtain HMRC clearance in advance. In practice, the performer (or agent) should apply using FEU8 and cite the treaty article; HMRC will then notify the UK payer if gross or reduced withholding is authorised. Without that authorisation, the payer must withhold at the standard 20% and the performer can later reclaim any over-deduction.

In summary, withholding tax targets payments for live (or recorded) performances and personal appearances. Payments that are purely non-performance or already taxed elsewhere (royalties, or fully taxed wages, etc.) are outside the scope. When in doubt, HMRC’s rule is conservative: if there’s any doubt about whether the person is UK resident or whether the payment should have tax, you’re safer to deduct withholding tax.

(Note: If a performer believes a tax treaty or exemption applies to them – beyond the standard scenarios above – they should proactively arrange a reduced withholding with HMRC. Absent HMRC’s clearance, a payer should not assume a treaty exemption and skip withholding on their own. Treaty relief must be claimed and confirmed by HMRC, usually via the FEU8 process described later.)

How UK Withholding Tax Works (Rates and Calculation)

When UK tax is due on a foreign performer’s income, it is collected through withholding by the payer. Here are the key points on rates and calculation of the tax:

• Basic Rate (20%) – The standard withholding tax rate on foreign entertainers’ earnings is the UK basic rate of income tax, which is currently 20%. Unless HMRC specifically authorizes a different rate, the payer should deduct 20% of the gross payment (above any personal allowance portion) as tax. This 20% flat rate serves as a payment on account toward the performer’s eventual UK tax bill. In many cases 20% will equal the performer’s final liability (since 20% is the basic income tax rate and many performers’ net profits fall into the basic band), but if the performer has very high income, the true liability could be higher – or if they have substantial expenses or treaty relief, the true liability could be lower. The withheld amount is a prepayment that will be credited against the final calculation.
• Apply 20% to Amounts Above the Threshold – If a single payment itself exceeds the personal allowance threshold, then effectively the first ~£12.5k of that payment is covered by the allowance and the rest is taxable. However, in practice HMRC doesn’t ask payers to do a nuanced calculation for each payment; instead, they say “if the total payments will exceed the threshold, deduct 20% from the outset.” For example, suppose a one-time concert fee is £40,000 to a non-resident artist. That clearly exceeds £12,570, so the promoter would withhold 20% of £40,000 (i.e. £8,000) to HMRC. If multiple smaller payments accumulate to over the threshold, refer to the guidance above on when to start withholding (essentially, start as soon as it’s foreseeable the threshold will be breached in total).
• No Graduated Rates – The payer does not attempt to calculate higher tax bands or anything complex. Even if the performer might technically owe higher-rate tax on their UK earnings, the withholding remains at a flat 20% in most cases. If additional tax is due (e.g. performer’s profit falls into the 40% bracket), HMRC will assess that through the performer’s Self Assessment tax return later – the payer isn’t responsible for withholding more than 20% (unless instructed otherwise by HMRC). By the same token, 20% is withheld even if the performer might ultimately owe less or nothing – any overpayment can be reclaimed by the performer from HMRC (see “Refunds” below). This standardized approach simplifies things for payers.
• Exclude VAT from the Tax Base – Importantly, VAT is not subject to withholding tax. If the payment to the performer includes any UK VAT component, you must exclude the VAT when calculating the 20% tax. In practical terms, most foreign performers will not be charging UK VAT on their fee (more on that in the VAT section), but consider a scenario where a venue pays a foreign act the gross ticket receipts from a show. Those ticket sales would include VAT charged to the public – before applying the 20% withholding, the VAT element must be stripped out. Withholding tax only applies to the performer’s income, not to taxes such as VAT.
• Handling Non-Cash Payments and Expenses: If you, as the payer, cover certain expenses for the performer or provide benefits (like free travel, accommodation, or equipment as part of the deal), HMRC’s rule is that those have to be treated as net of tax – effectively, the tax on those benefits must be grossed-up and paid from your own pocket. For example, if you purchase a £1,000 plane ticket for the performer as part of the contract, that £1,000 is considered income to the artist. You shouldn’t deduct £200 from the ticket itself (since you can’t really withhold from a plane ticket you bought), so instead you must calculate and pay HMRC the 20% (£250 in this case, on a grossed-up equivalent of £1,250) separately. There is an option to avoid this gross-up in some cases by applying for a special clearance – see “Reduced Tax Applications for Expenses” below, or coordinate with the performer to deduct that tax from their fee if they agree.

In summary, most payers will simply apply a 20% flat deduction on the performance fees and pay that to HMRC. Don’t include any VAT in that base, and start withholding once the personal allowance is effectively used up. Keep in mind this is an advance tax payment – final liability may differ, but that’s between HMRC and the performer. Your job is to calculate 20% on the relevant amounts and remit it.

HMRC Registration and Reporting Requirements for Payers

If you are a UK-based promoter, agent, venue, or other payer of a foreign performer, you have certain obligations to register and report these payments to HMRC’s Foreign Entertainers Unit (FEU). Here is a step-by-step breakdown of what you need to do:

1. Register with the Foreign Entertainers Unit (FEU) before paying the performer. Prior to making any payments to a non-UK resident entertainer or sportsperson for a UK performance, you must contact HMRC’s Foreign Entertainers Unit to register as a payer for withholding tax. There isn’t a standard form to start; typically, you write to HMRC (on company letterhead) or call them, providing your company name, address, and a contact person/number. Once registered, HMRC will set you up with quarterly reporting for this withholding scheme. They will issue you a unique reference and send you Form FEU1 at the end of each quarterly period.

2. Withhold 20% from the performer’s payment as required. Following the rules described above, deduct tax at basic rate on any payment (or series of payments) above the threshold. If the performance fee is under the threshold and you have no reason to expect further payments in the year, you can pay gross (no deduction). If you do deduct tax, keep a record of the gross amount and the tax withheld for each payment – you’ll need these for reporting. Remember that if you pay through an intermediary (like the performer’s agent), you generally still must withhold tax, unless that agent is on HMRC’s special middleman scheme (in which case they handle it). When in doubt, deduct the tax – you can be held liable for any tax that should have been withheld but wasn’t.

3. Complete quarterly FEU1 returns and pay HMRC. The FEU1 is the quarterly tax return for foreign entertainers’ withholding. HMRC will send you a form FEU1 for each accounting period (quarter). The standard quarters end on 30 June, 30 September, 31 December, and 5 April (aligned with the UK tax year end of 5 April). Your task is to fill in the FEU1 with details of every payment to foreign entertainers you made in that quarter even if no tax was deducted on some payments. For each payment, you’ll list the performer’s name, address (or their agent’s, depending on who was paid), the gross amount, and the amount of tax withheld (if any). If you had more entries than fit on the form, use a continuation sheet (form FEU1(CS)) or attach a spreadsheet with the required data.

You must submit the FEU1 return and pay the withheld tax to HMRC within 14 days after the quarter-end. For example, for quarter ending 30 June, the payment and return are due by 14 July. HMRC provides an Accounts Office reference for payments (often the Shipley Accounts Office is used for these payments). Be punctual – late payment could incur interest or penalties, and remember that until you submit the form correctly, the performer doesn’t get credit for the tax.

4. Issue the performer a tax deduction certificate (Form FEU2). Whenever you deduct tax from a payment, you are required to give the performer evidence of the tax withheld. This is done with Form FEU2, the Foreign Entertainers Tax Deduction Certificate. After deducting tax, fill out an FEU2 for that payment – it’s a simple certificate noting the gross fee and the tax withheld. You need to print and sign three copies of each FEU2:

• One copy to send to HMRC, attached to your quarterly FEU1 return for that period.
• One copy to give to the performer (or their agent whom you paid).
• One copy to keep in your own records for reference.

All copies must be originals (signed); you cannot issue duplicate certificates later, so take care to produce the required copies at the time of payment. The FEU2 form is available as an online form on GOV.UK which you fill in and print out. 

5. Maintain records and stay compliant. Keep a log of all payments to foreign performers, whether or not tax was withheld, as you’ll be reporting all such payments every quarter. If circumstances change (e.g. you engage an additional foreign act last-minute), remember to include them. Also, monitor if any performer might approach the threshold across multiple engagements with you, so you know when to start withholding.

If you’re unsure about any payment, contact the FEU for guidance. HMRC’s Foreign Entertainers Unit can also advise if a performer has obtained a reduced tax rate (they would send you an authorization if so). Always err on the side of caution – if the entertainer’s residency is unclear or you suspect they are non-UK, HMRC says to deduct withholding tax. It’s better to withhold and later have the performer claim a refund than to not withhold and find out HMRC expected you to.

Finally, note that failure to operate the withholding correctly can leave the payer liable. If you didn’t deduct when you should have, HMRC can ask you (the UK payer) to pay the tax out of pocket so compliance is important.

Applying for Reduced Tax (Gross Payment) with Form FEU8

In some cases, a foreign performer may expect that the standard 20% withholding will exceed their actual UK tax liability – for example, if they have large deductible expenses, or if a tax treaty should exempt their income, or if they are only making a small profit. Rather than suffer excessive withholding and wait for a refund, the performer can apply in advance for a reduced rate of withholding (even down to 0% in appropriate cases). This is done using Form FEU8, the Reduced Tax Payment application.

Who can apply: The application is typically made by the performer themselves or their authorized representative (which could be their agent or accountant). It can cover an individual performer, or an entire group/ensemble, or a whole tour’s engagements in one go. 

When to apply: The application must be submitted before the payment is made, ideally at least 30 days before the payment date. Each tour or series of performances in the UK usually needs a separate application. If new appearances are added or details change (or an engagement is cancelled) after an application, you should send an updated FEU8 to HMRC to reflect the changes.

How to apply: Fill in Form FEU8 with details of the engagements and expected income and expenses. HMRC provides an interactive online form for FEU8 on the GOV.UK website. You complete it and then print it out and post it to HMRC at the address given on the form (HMRC Charities, Savings and International, BX9 1AU, UK).

• Information needed: The form will ask for the performer’s details, the dates and nature of the UK appearances, the expected fees or prize money, and critically, an estimate of related expenses or grounds for reduced tax. Essentially, you’re showing HMRC what you anticipate your net taxable profit will be so they can set a withholding rate closer to that. You do not need to send all backup documents with the initial FEU8 in most cases – just the form. However, HMRC might request supporting evidence after reviewing the application.
• Supporting evidence (if requested): HMRC has indicated the types of evidence they may ask for to substantiate a reduced rate request. For example:
  • A film actor might be asked for a shooting schedule detailing how many days of filming were in the UK versus worldwide, so HMRC can apportion the income.
  • A performing group or company might need to provide a list of all performers, their countries of residence, a breakdown of payments to each, and copies of some contracts. This helps HMRC see how the fee is divided and ensure each member’s personal allowance (if applicable) is considered.
  • Musicians or bands should be ready to show the UK tour contract, and details of income streams like merchandise sales, sponsorship, record company support, etc., related to the UK performances. HMRC will exclude purely non-UK income (like royalties on recordings sold outside the tour) but include things like on-site merchandise sales in UK, so providing that breakdown helps.
  • For sportspeople, if the earnings are performance-based (e.g. prize money depending on results), it may be tricky to apply in advance unless there’s guaranteed money. If an application isn’t feasible beforehand (like a tournament where you only know earnings after winning), the withholding at 20% will occur and the athlete can sort out the exact tax afterward. But for things like appearance fees or sponsorship, a sports star can apply to reduce withholding, often by apportioning worldwide endorsement income to UK based on days spent competing or training in the UK (HMRC uses methods like Relevant Performance Days to calculate the UK portion of global endorsement deals).
  • For public funded performances covered by treaty, gather evidence such as funding award letters/contracts from the relevant public body (e.g., in France that would be Ministère de la Culture, DRAC, Institut français, a théâtre national/other EPIC/EPA), plus a visit budget showing that public funds cover the majority of costs.

What happens next: HMRC will review the FEU8 application. If they agree that a lower rate is justified, they will issue an authorisation (Form FEU4) to the payer specifying the rate to deduct. For instance, HMRC might authorize a 0% rate (gross payment) if they conclude the income will be fully offset by allowable expenses or exempt by treaty, or they might authorize a reduced rate like 5% or 10% depending on the circumstances. The payer should wait for this authorisation before paying gross or at a reduced rate – without the FEU4 in hand, the default 20% must be withheld.

If HMRC does not grant a reduction (or the application isn’t processed in time), the payer should go ahead and deduct the full 20%. The performer can then reclaim any overpaid tax later (see next section). Note that an FEU8 reduced withholding approval only affects the upfront deduction; the performer will still later compute their actual tax due. The goal is simply to align the withholding closer to the likely true liability so there isn’t a huge refund or balance due.

Key tip: Send in FEU8 applications as early as possible – at least 30 days in advance is required, but earlier is better, especially for complex tours. If, for example, you’re planning a UK tour next summer, you could submit the FEU8 with projected income/expenses for all shows on that tour in one go. HMRC will then calculate an appropriate withholding (often they’ll determine a net profit ratio and tell the promoter to withhold tax only on that net portion). They will send the notification of the approved withholding rate to the payer of the income who then implements it.

By using FEU8, foreign performers can avoid excessive cash flow loss and the hassle of large refunds, and promoters/agents benefit by knowing exactly how much to deduct (maybe nothing) rather than defaulting to 20%. It’s a bit of upfront paperwork, but for sizeable engagements or tours, it’s well worth it.

Claiming a Refund of UK Withholding Tax

If a foreign performer ends up having too much tax withheld – for example, the standard 20% was deducted on gross fees but after deducting allowable expenses their actual tax due is lower, or they never breached the personal allowance after all, or a treaty applies – they can claim a refund from HMRC. There are two main ways this can happen: via direct refund claim, or via filing a Self Assessment tax return.

Direct Refund Claim: After the end of the UK tax year (5 April), an entertainer or sportsperson who believes they overpaid can submit a refund claim to HMRC’s Foreign Entertainers Unit. To do this, they should write to HMRC and include the following:

• The original FEU2 tax deduction certificates for all relevant payments (this is why retaining those certificates is important).
• A summary of expenses related to their UK performances (to show why the taxable profit is lower than the gross income).
• A copy of the contract(s) with the payer, if available (to verify the terms and any income splits).
• Details of any other UK income received in that tax year (so HMRC has the full picture).
• Personal details: full name, personal address, as well as nationality and country of residence.
• A signed declaration stating to whom the refund cheque should be payable and the address to send it (e.g. the performer or perhaps their company, depending on arrangements).

All this should be sent to the FEU at HMRC (address: Charities, Savings and International 1, HMRC, BX9 1AU, United Kingdom). You do not need to calculate the refund yourself; just provide the information. HMRC will review and determine if too much was paid.

If the claim is straightforward – say, the performer had £5,000 withheld but final liability is £3,000 – HMRC will process a repayment of the £2,000 difference. If the situation is more complex, HMRC may ask the performer to complete a UK Self Assessment tax return to formally compute the tax.

Self Assessment route: In some cases, the performer is actually required to file a tax return – for instance, if HMRC sends them a notice to file, or if the withheld tax did not cover all their UK tax liability. But a performer can also choose to file a Self Assessment return proactively to reconcile their tax. By filing a return, they can declare their actual income and expenses and claim any overpayment as a refund through the return. The helpsheet HS303 is available to guide non-resident entertainers through the return process. Filing a return is often advisable if the performer has multiple sources of UK income or a complex situation (so that everything is accounted for in one calculation). For a single engagement with clear over-withholding, a letter with FEU2s as described above should suffice. 

What if not enough was withheld? It’s worth noting the opposite scenario: if the 20% withheld ends up being less than the actual tax due (for example, maybe the performer’s UK profit was large enough that higher-rate tax applies, or they had other UK income). In that case, the performer must pay the balance to HMRC. Typically, they should notify HMRC by 5 October following the tax year and file a Self Assessment return reporting the additional tax due. HMRC will then bill the performer for the difference. The payer’s responsibility is only to withhold at 20% (unless instructed to do more); any shortfall is settled directly by the entertainer with HMRC. So the withholding is a two-way safety net: refunds for overpayments and additional billing for underpayments ensure the final tax is correct.

Time frame: How long do performers have to claim? Generally, claims should be made within the normal statute of limitations (currently four years from the end of the tax year). But the sooner the better – once you have all final figures for the tax year, you can submit a claim. Expect a few months for HMRC to process a refund claim, especially if they request more info.

In summary, no money is ultimately lost if too much was withheld – HMRC will return the excess to the performer, provided the proper claim or return is made. Keeping all FEU2 certificates and receipts of expenses will make the refund process smooth.

VAT Implications for Foreign Performers and UK Agents/Promoters

UK Value Added Tax (VAT) is a separate consideration from income tax, but it often comes into play in performance arrangements. Both foreign performers and the UK entities hiring them should be aware of how VAT is handled:

• No VAT on Withholding Tax Calculation: As noted earlier, when calculating the 20% withholding tax, exclude any VAT component. If a performer’s fee invoice includes VAT or if the payment includes ticket sale VAT, that portion is not the performer’s income and should not be taxed as such.
• Performance fees and place of supply: The general rule for services is that if a service is supplied by a non-UK provider to a UK business, the place of supply is the UK and the reverse charge mechanism applies for VAT. However, in the case of entertainment services, there has historically been a special rule: the service of an entertainer performing in person is taxed where the performance is carried out (the UK, in our case). In practice, these two rules coincide to the same result – the performance is in the UK. For UK-based promoters (who are VAT-registered), the norm is to account for UK VAT on the performer’s fee via the reverse charge procedure. Example: A UK promoter contracts a non-UK band for a concert. The band’s company is not UK-established. The band invoices £50,000 for the show. They do not add UK VAT on the invoice (since they aren’t UK-registered). The UK promoter, being VAT-registered, must self-account for VAT on this £50,000 under the reverse charge (output VAT of £10,000 at 20%, and equivalently claim input VAT of £10,000 if the cost is business-related). The band doesn’t need to register for VAT in the UK in this scenario. The promoter effectively handles the VAT internally. From the band’s perspective, they simply receive the net payment (minus any withholding tax) and have no VAT obligations in the UK.
• What if the promoter is not VAT registered? If the UK payer is not VAT-registered (e.g. a small venue below the VAT threshold or a private individual), the reverse charge cannot apply. In that case, the foreign performer might indeed have a requirement to register for UK VAT because the place of supply is the UK and the customer can’t self-account. There is no registration threshold for non-UK businesses making supplies in the UK to non-business customers – so even a single gig could trigger a requirement for the performer to register and charge UK VAT on their fee. This is a complex area, but in general most professional engagements involve VAT-registered promoters or ticket sales, etc. If you are a foreign performer dealing with a non-business client, seek VAT advice. For most B2B contexts, the reverse charge simplifies things and you won’t need a UK VAT number.
• UK-based agents’ services: If a UK-based agent or promoter provides services to a foreign performer (for example, a UK agent arranges a tour and charges the artist a commission), that agent’s services are subject to normal VAT rules. The place of supply of intermediary services can vary, but if the foreign artist is outside the UK, often the agent’s service (when arranging a performance in the UK) might still be considered supplied where performed (complex rules). However, many agents will zero-rate their service if the “place of supply” is outside UK. On the other hand, if a UK promoter is paying an agent’s fee in the UK, that agent will charge VAT. The key takeaway for performers: UK agents/promoters will likely charge VAT on their fees if applicable, so budget that into your costs. This VAT an overseas performer pays to a UK agent might be reclaimable via a VAT refund scheme for overseas businesses if not registered – the UK has a mechanism for non-UK businesses to claim back UK VAT on certain expenses (formerly via EU 13th Directive equivalent).
• Ticket sales: When audiences are charged for admission (tickets), those sales are usually subject to UK VAT (20% on ticket price) unless the event qualifies for a cultural exemption (certain theatrical/dance events can be exempt if run by eligible bodies, etc.). Usually the promoter or venue running the box office handles charging and remitting VAT on ticket sales. The performer typically doesn’t handle that unless they self-promote the event. If a foreign performer is effectively self-promoting a show (renting a venue and keeping ticket revenue), then they are making taxable supplies of admission in the UK, which likely forces them to register for VAT and charge VAT on tickets. This is a niche scenario; more commonly, a UK promoter takes on that responsibility.
• Receiving gross ticket receipts: As mentioned, if a venue simply passes gross ticket receipts to a foreign act as payment, the VAT element in those receipts must be carved out. For instance, suppose £100,000 gross came in from ticket sales, which includes £16,667 VAT (at 20%). The performer’s fee in that case is actually £83,333 net. Withholding tax (20%) would apply only on the £83,333, not on the full £100k. The £16,667 is VAT that the venue or someone must pay to HMRC from the ticket sales. Often, contracts will specify fees net of VAT or clarify who is responsible for VAT on tickets.

Summary for foreign performers: In most cases you will not have to register for UK VAT if you are hired by a UK entity – the UK promoter will handle any VAT via reverse charge, and you simply get paid (with withholding tax taken off). However, if you do a lot of business in the UK (multiple tours, merchandise sales, etc.), you might voluntarily register for VAT to recover UK VAT on your tour expenses. Some large touring artists do this – they register as a “non-established taxable person” in the UK so they can reclaim VAT on tour costs (venues, advertising, etc.), and charge VAT to the promoter (which the promoter can recover). This is a strategic decision and requires tax advice.

Summary for UK agents/promoters: Ensure you do not deduct withholding tax on any VAT amounts you handle – keep VAT accounting separate. Use reverse charge accounting for fees paid to overseas performers when applicable. Also, remember that your own income (your commission or the ticket sales) is subject to the normal VAT rules – the foreign performer’s withholding tax does not affect your VAT obligations. So, you might be paying 20% to HMRC on the performer’s behalf for their income and separately paying 20% VAT on your ticket sales to HMRC – they are different things, and both must be accounted for. 

In short, VAT and entertainer withholding operate independently: one is a sales tax on transactions (handled by whoever the supplier is), the other is an income tax on the performer’s earnings (withheld by the payer). Both need attention in cross-border entertainment arrangements, but one does not offset the other.

In conclusion, foreign performers and their UK hosts should assume the longstanding rules continue to apply unless they hear otherwise from official channels. Always refer to the latest HMRC guidance before an engagement – but as this guide has detailed, the fundamentals (20% withholding, FEU forms, etc.) are stable. By following the procedures and keeping documentation, both performers and promoters can manage the UK tax aspect smoothly and avoid surprises.