The use of someone’s image rights can essentially be explained as the practise of appropriating someone’s personality.2 In our modern society today, people have become transfixed with sport stars, which led to the image rights of individual sport stars such as Lionel Messi and Cristiano Ronaldo to become commodities, as these rights are now being exploited by their clubs and other third parties in order to enhance their brand image and to promote the sale of their products.3 This use of the image rights of super stars had led to a whole new source of income for these sport stars. 

Due to these relatively high amounts of income received for the use of a sport star’s image, they may be tempted to enter into creative schemes to try and diminish high taxes levied against these income streams. Both Messi and Ronaldo have used ‘image rights companies’ (hereafter referred to as ‘IRC’) to manage their image rights and to reduce their tax liabilities. 

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