A creator's income usually runs through four jurisdictions at once: the author's country of tax residence, the country of the paying platform, the countries of the audience, and the country where a company is registered or an account is held. Each adds a requirement of its own — withholding at source, characterisation of the income, platform reporting, ad-disclosure and ad-admission rules.
The hub arranges the cluster's articles into a single sequence: the types of income stream and their tax character; platform withholding and reporting; the choice between an individual, a personal company and a holdco; relocation and talent visas; advertising regulation and liability for promos. The sections answer the question of where to look and how things connect — the detailed figures and procedures live in the child articles.
The order matters. The character of the income and the withholding are counted first, the base country is chosen second, the structure is built last. UAE tax residence on its own leaves the American 30% withholding on revenue from the US audience in place: there is no UAE–US tax treaty, and there is nothing to credit that tax against.
Concept
The creator economy differs from a classical business in the source of value: payment is made for the audience's attention and for rights — to content, image and voice. Tax characterisation therefore depends on how the payment is papered. The same integration can be a royalty, a fee for services or a licence of image rights, and each variant carries its own sourcing rules, withholding and treaty relief.
The second difference: the payment infrastructure sees the author before the home tax authority does. Platforms withhold tax on the day of payout and report their sellers, banks count cross-border payments one by one. The year is therefore worked through in three passes: income streams and their character; withholding and reporting; base, visa and structure.
Income streams and how each is taxed
Platform payouts — AdSense and YouTube Shorts, Twitch, TikTok, Patreon — are legally a blend of royalties and fees for services; the split is set by the platform's own terms. For non-US persons the part attributable to the American audience is taxed at source on the day of payment: the platform — Google for YouTube, for example — acts as withholding agent. The platform-by-platform mechanics are in platform withholding, the general theory in withholding tax.
Brand contracts and sponsorship are fees for services: the income follows the place where the author physically performs the work, and for concerts, shows and live appearances the country of performance becomes relevant. The touring author's calendar, and how tax authorities reconstruct it from the digital trail, is covered in tax residence on tour. Adjacent regimes: US college athletes' name-image-likeness deals in NIL, esports contracts and prize money in esports visas and taxes.
IP royalties are licences of the catalogue, music, courses, trade marks and image. For US tax, the source of a royalty is the place where the right is used (§ 861(a)(4) IRC), so the geography of the tax is set by the audience. A sale of the catalogue by the author personally runs into § 1221(a)(3) IRC: creative work in the hands of its creator does not qualify as a capital asset. Structures that move rights into a company are in creator holdco; the legal status of the image is in image rights.
Tokens, donations and subscriptions form the most heterogeneous stream. Tax authorities treat stream donations as income from an activity: the IRS treats income from creative services and other on-demand work arranged through apps and websites as taxable gig-economy income. Subscription platforms, after the EU Court of Justice ruling in Fenix, C‑695/20, pay VAT on the full subscription price themselves as deemed supplier — the economics of the niche are in OnlyFans taxes. Issuing or promoting tokens adds securities-law exposure — covered in the advertising section.
The stream summary shows where tax arises on each flow and who reports the payment.
| Stream | Tax character | Who withholds or reports | Deep dive |
|---|---|---|---|
| Platform revenue | royalties + services, split set by the platform | the platform: 30% of the US share, up to 24% without a tax form | Platform withholding |
| Brand contracts, appearances | services where the author works; shows taxed where performed | the client or tour promoter under the contract | Tax residence on tour |
| IP royalties and the catalogue | royalties by place of use; a sale hits § 1221(a)(3) IRC | the licensee; on a sale, the author personally | Creator holdco |
| Donations, subscriptions, tokens | income from an activity; VAT paid by the platform | payment providers (CESOP), platforms (DAC7) | OnlyFans taxes, DAC7 |
Of the four streams, only brand contracts usually arrive without an intermediary agent, so on those the author personally answers for advance tax payments and VAT at home.
Platforms: withholding and reporting
US withholding applies on the day of payment. Google withholds 30% of the YouTube revenue share attributable to US viewers where no treaty rate is claimed; without tax information from an individual creator, up to 24% of total worldwide earnings is withheld. A W‑8BEN remains valid until the end of the third calendar year after signature, and the treaty rate for residents of countries with a working agreement drops to 0–10%.
European reporting runs in parallel with the withholding. Under DAC7 a platform files annually, for every seller, the consideration broken down by quarter, the TIN and the account details; personal services carry no monetary threshold — the report goes out from the first transaction, and the only carve-out applies to goods below 30 sales and €2,000 a year. The UK's MRDP have applied since 1 January 2024. The full architecture and the reconciliation drill are in the platform transparency overview.
The US Form 1099-K, after the One Big Beautiful Bill Act, has reverted to the $20,000-and-200-transactions threshold, while CESOP has, since 1 January 2024, collected from EU banks and payment providers the details of any payee receiving more than 25 cross-border payments per quarter — whether or not a platform is involved at all. A gap between the platform's report and the return is found automatically; an address and TIN left un-updated after a move send the data to the former jurisdiction.
Four reporting regimes run in parallel and on different grounds.
| Regime | Who reports | Threshold | In force from |
|---|---|---|---|
| DAC7, EU | the platform | services — no threshold; goods — from 30 sales or €2,000 a year | — |
| MRDP, UK | the platform | services — no threshold | 1 January 2024 |
| 1099-K, US | the payment intermediary | $20,000 and 200 transactions | after the One Big Beautiful Bill Act |
| CESOP, EU | banks and payment providers | more than 25 cross-border payments a quarter | 1 January 2024 |
VAT on digital services is closed off by the platform: after Fenix, a subscription service as deemed supplier charges the tax by the subscriber's country. Direct sales from the author's own site — merch, courses, paid communities — stay with the author, together with VAT and GST thresholds across the buyers' countries; the practice is worked through in OnlyFans taxes.
Structure: individual, personal company, holdco
An individual, or the local equivalent of a sole trader, is the working default: minimal reporting, direct access to treaty relief, transparent withholding. A company earns its place once there are a team, a catalogue, deferred brand payments and profit to reinvest with no reason to distribute it to the personal level.
The personal company and IR35
A personal company adds reclassification risk. The UK's IR35 rules test contracts run through a personal service company for disguised employment: Chapters 8 and 10 of Part 2 of ITEPA 2003, with an offset, from 6 April 2024, for taxes the worker has already paid. Relocation adds the place-of-management question: a company left behind in the old country may keep its corporate residence there. The full analysis is in PSC and IR35.
The holdco: catalogue, brands, investors
A holdco solves a different problem — turning reach into capital: own product brands, a catalogue sale, outside investors. The § 1221(a)(3) IRC trap makes the sequence of moving rights critical — creator holdco works the options. Home-country CFC rules can attach to such a company: for a Russian tax resident, for example, a foreign company becomes a CFC under art. 25.13 of the Russian Tax Code at a stake above 25%, or above 10% where Russian residents together hold more than 50% — with the notifications and reporting of the CFC rules.
Image and voice rights
Image and voice rights are an asset of their own, and where they sit should be a deliberate choice. The legal regime of a person's image differs by country, and that changes the tax pricing of licences too: the analysis is in image rights. AI copies of voice and likeness are covered in publicity rights in the AI era. A licence from the author to their own company must be paid for and priced at arm's length.
Relocation: the base jurisdictions
Three parameters drive the choice of base: the US share of the audience and the existence of a working US treaty, the character of the streams, and the cost of entry and living. The five popular routes — Dubai, Portugal, Spain, Serbia, Kazakhstan — with procedures and the banking side are assembled in creator relocation.
The regime matrix: fifteen bases on common axes
The axis that decides most cases is the fourth column. Several of the headline regimes were drafted around employment income and are closed to a creator who invoices as a self-employed person, while the regimes that were drafted for individuals carrying on their own activity — Turkey's content-producer exemption, Italy's forfettario, Georgian small business status, Serbian paušal — are the ones that actually fit a platform income mix.
| Base | Regime | Rate and ceiling | Open to a self-employed creator? | US treaty rate on copyright royalties | The condition that decides eligibility |
|---|---|---|---|---|---|
| UAE | no personal income tax; corporate tax on business income | 0% personal; 9% corporate | yes — there is no personal income tax | no treaty: 30% | 9% corporate tax for an individual once turnover from the business passes AED 1,000,000 |
| Turkey | content-producer exemption, mükerrer art. 20/B GVK | income-tax exemption against a final 15% withheld by the bank | yes — written for individual content producers | 10% | all revenue through one dedicated Turkish account; the exemption lapses above the fourth bracket of art. 103 GVK |
| Italy | regime forfettario, art. 1 commi 54–89 of Legge 190/2014 | 15% substitute tax, 5% for the first five years of a new activity | yes — open to individuals with a partita IVA only | 0% | revenue ceiling €85,000; a cap on staff costs |
| Italy | impatriati, D.Lgs. 209/2023 | 50% of income out of the base, ceiling €600,000 | yes — self-employment income sits inside the regime | 0% | five tax periods; entry conditions in the regime's own deep dive |
| Georgia | small business status for a sole trader | 1% of turnover, 3% above the ceiling | yes — the regime exists only for sole traders | 0%, under the 1973 US–USSR treaty | GEL 500,000 ceiling; royalties outside the regime at 20% |
| Kazakhstan | simplified declaration, Tax Code (Law No. 214-VIII of 18.07.2025) | 4% of income | yes | 10% | ceiling of 600,000 MRP, from 1 January 2026 |
| Serbia | lump-sum (paušal) entrepreneur | lump-sum tax instead of accounting for actual income | yes — entrepreneur registration is the entry | no treaty: 30% | application on registration, or by 31 October for the following year |
| Armenia | micro-business, Tax Code | exempt within the statutory ceiling | yes | 0%, under the 1973 US–USSR treaty | the ceiling is set by the Tax Code |
| Cyprus | non-dom | dividends and interest out of the defence contribution; the activity on the ordinary scale to 35% | the non-dom exemption yes; the 50% relief on employment income no | 0% | 17 years, then €50,000 a year in five-year blocks; GHS 2.65% on dividends and interest, 4% on self-employment income, on a base capped at €180,000 |
| Andorra | IRPF | rates in the tax-system deep dive | yes | no treaty: 30% | passive residence €1,000,000 from 13.02.2026; the science, culture and sport track without investment |
| Portugal | IFICI, Portaria 352/2024/1 | 20% on qualifying income | category B income is inside the regime, but content creation is not on the activity list | 10% | EQF level 6 plus three years, or level 8 in a qualifying organisation; register by 15 January |
| Spain | Beckham, art. 93 of Ley 35/2006 | 24% up to €600,000, 47% above, six tax periods | no — employment or director relationship, plus the narrow Ley 28/2022 limbs | 0% | art. 93.2.b makes employment income Spanish wherever the work is done; sportspeople excluded by RD 1006/1985 |
| UK | FIG regime for new arrivals | foreign income and gains out of the base for four years | yes — the regime is neutral as to status | 0% | ten years of prior non-residence; the personal allowance is given up for the years claimed |
| US | no creator-specific regime | ordinary scale plus self-employment tax | not applicable | not applicable | § 1221(a)(3) IRC: the author's own catalogue gets no capital-gain treatment |
| Russia | NPD, the self-employed regime | 4% on receipts from individuals, 6% from companies | yes — the regime exists for individuals only | no rate: the treaty is suspended | RUB 2.4 million a year ceiling |
Read down the fourth column and the choice set shrinks sharply. Spain's Beckham regime, Portugal's IFICI and the Cypriot 50% relief on employment income are the three most frequently recommended European bases for creators, and all three answer "no" or "in practice no" for a creator who invoices as a self-employed person. The regimes that answer "yes" fall into two families: turnover regimes with a low headline rate and a hard ceiling (Georgia, Kazakhstan, Serbia, Armenia, Italy's forfettario, Turkey's art. 20/B), and bases with no turnover ceiling (UAE, Andorra, Cyprus on the investment leg).
The fifth column then reorders the first. A turnover regime and a treaty rate work in opposite directions: Georgia taxes the activity at 1% and leaves copyright royalties from the United States untouched under the 1973 treaty, while the UAE taxes the activity at nothing and leaves the American 30% in place. On a revenue mix where the US audience is half the total and most of it is characterised as royalty, that 30% outweighs any difference between a 1% and a 4% turnover rate. The order of calculation therefore runs: US share and characterisation first, treaty rate second, local regime third.
The ceilings are the second thing that reorders the list. A turnover regime is a regime for a defined size: GEL 500,000 in Georgia, €85,000 in Italy, the fourth art. 103 bracket in Turkey, 600,000 MRP in Kazakhstan. Growth through the ceiling is not a rate change but a regime change, usually mid-year and usually with the activity already registered under a code that the new regime treats differently. A creator whose revenue is doubling annually chooses a base for the revenue two years out, not for this year's.
| Profile | Base that fits | Why |
|---|---|---|
| Platform revenue, US audience above a third, revenue under €85,000 | Italy forfettario or Georgia | 0% treaty rate on royalties plus a low turnover rate; the ceiling is not yet binding |
| Platform revenue, audience mostly outside the US, growing fast | UAE | no ceiling and no personal tax; the missing US treaty costs little on a non-US audience |
| Content producer with revenue in Turkish lira and a Turkish audience | Turkey, mükerrer art. 20/B | a final 15% withheld at the bank replaces filing altogether, within the bracket ceiling |
| Brand contracts through a company, salary paid to self as director | Spain Beckham or Italy impatriati | these are the regimes that reach employment income; the director limb is the entry |
| Catalogue and dividend income, activity largely wound down | Cyprus non-dom | dividends and interest out of the defence contribution for 17 years |
| Arriving in the UK with foreign catalogue income | UK FIG | four years of foreign income and gains out of the base, status-neutral |
Dubai remains the zero-personal-income-tax base with a Golden Visa for content creators valid for up to ten years on a Creators HQ nomination and a 4–10 week cycle; 9% corporate tax switches on for an individual above AED 1,000,000 of turnover from the business. The visa, licensing (media permits included) and tax circuits are in the UAE hub; the residence tests and the certificate in UAE tax residency. The UAE has no US treaty: the American 30% stays regardless of the visa.
Spain offers the Beckham regime: 24% on employment income up to €600,000 a year and 47% above it, for six tax periods under Article 93 of Ley 35/2006. Two limits decide whether a creator can use it at all. Article 93.2.b treats employment income as Spanish for the whole period of the election, wherever in the world the work is done, so the regime is a rate on a salary rather than a shelter for foreign earnings. And its personal scope is an employment or company-director relationship, plus the narrow entrepreneurial-activity and highly-qualified-professional limbs added by Ley 28/2022, each with its own certification: a creator invoicing as a self-employed person carrying on an economic activity does not qualify and runs on the general scale, and professional sportspeople are excluded outright by RD 1006/1985 — the detail is in Spain and athletes. Entry runs through Spain's DNV, and the rest of the country's picture is in the Spain hub. In Portugal, IFICI applies — a regime for science, teaching and innovation companies; content creation is not on its list of activities.
In Andorra passive residency rose to €1 million on 13 February 2026 (Llei 2/2026, del 22 de gener, de continuïtat i consolidació de les mesures per al creixement sostenible; BOPA núm. 15 of 12.02.2026), while the science, culture and sport track runs with no investment — a €47,500 deposit and 90 days of presence — Andorra's tax system.
Serbia takes authors through lump-sum (paušal) taxation of an entrepreneur; Kazakhstan, from 1 January 2026, through the simplified declaration at 4% of income with an annual cap of 600,000 MRP (new Tax Code of Kazakhstan, Law No. 214-VIII of 18 July 2025).
On top of any base, touring authors carry tax residence on tour; the mass entry point with no employer and no investment is digital nomad visas. The price of leaving the old base is costed in the exit tax overview, moving the savings in pensions on relocation, and spreading base, passport and accounts in the five flags theory.
Talent visas
Eight routes work with no employer and differ in who certifies the achievement.
| Route | Who certifies, and what is tested | Term | The catch |
|---|---|---|---|
| O-1B, US | USCIS on the petition: three of the six criteria in 8 CFR 214.2(o)(3)(iv) | up to three years, extendable in one-year steps | premium processing $2,965 from 1 March 2026; a petitioner or agent is required |
| Global Talent, UK | Arts Council England endorsement for arts and culture | up to five years | settlement after three years for recognised leaders, five for promise |
| Golden Visa, UAE | Creators HQ nomination — the UAE hub | up to ten years | 4–10 week cycle; media licensing is a separate circuit |
| Passeport Talent, France | the prefecture on the CESEDA talent grounds; the artist track requires resources of at least 70% of the full-time gross SMIC per month of stay, at least 51% of them from the artistic activity | up to four years, renewable | the ground has to be chosen correctly at filing — artist, renown, or business creation |
| Self-employment permit, § 21 AufenthG, Germany | the Ausländerbehörde, assessing the activity as a business case | up to three years, then settlement | no dedicated creator track; the file is a business case, assessed locally |
| Self-employed residence permit, Netherlands | the IND, assessing the business plan; self-employed artists have a route of their own | set by the IND | the file is judged as a business case, not by audience |
| Self-employed Persons Program, Canada | IRCC, on cultural or athletic experience plus intended self-employment | permanent residence | acceptance of new applications paused from 30 April 2024 (Ministerial Instructions 72) |
| National Innovation visa, subclass 858, Australia | a nominator plus the Home Affairs assessment of an internationally recognised record | permanent residence | replaced the Global Talent visa on 6 December 2024 |
The eight split into two mechanisms. O-1B, Global Talent, Passeport Talent and the Australian 858 are certification routes: a third party attests to the record, and audience metrics are evidence rather than a criterion. The German § 21 permit, the Dutch points route and the Canadian programme are business-case routes: the file describes an activity and its economics, and a platform income history is read as turnover. The UAE Golden Visa sits between the two — the nomination is a certification, but it is issued by a body set up to attract the sector.
Models and performers travel separate tracks with petition logic of their own — talent routes for models and artists; esports players go through gaming petitions and sports categories — esports visas and taxes.
Advertising, promos and liability
Ad disclosure has become a licence-and-fines zone. The US runs on the FTC Endorsement Guides, 16 CFR Part 255: a material connection with the brand is disclosed in the post itself. The comparison of market access across twelve jurisdictions is in influencer regulation.
Promoting financial products carries a charge of its own. The SEC fined Kim Kardashian $1.26 million under Section 17(b) of the Securities Act for an EthereumMax post that omitted the $250,000 payment. The offences, insurance and celebrity case law are in celebrity promo liability.
Gambling sponsorship is contracting by regulation: Premier League clubs agreed to withdraw gambling brands from the front of matchday shirts from the 2026/27 season, and the licensing white lists and targeting rules are worked through in gambling sponsorships. Every bookmaker integration is checked against the audience's country, the advertiser's licence and the age targeting.
The Russia hub
Inside Russia: obligations for owners of pages with an audience above ten thousand users (art. 10.6 of Law No. 149-FZ), the advertising identifier (erid) under art. 18.1 of the Advertising Law, the ban on advertising on information resources with restricted access (art. 5(10.7)) and VAT under the simplified regime from 2026 for income above RUB 20 million for 2025 (art. 145 of the Tax Code). All of it, including enforcement practice — business splitting, laundering, currency offences — is in the deep dive on regulating the infobusiness.
On the way out: there has been no US treaty rate for Russian tax residents since 16 August 2024, and Article 232 of the Russian Tax Code blocks crediting the American 30% at home — consequences in the suspension of Russia's tax treaties; income earned through Russian internet infrastructure from Russian companies or entrepreneurs, or paid into a Russian bank account, remains Russian-source after the move (art. 208(1)(6.3) of the Tax Code). Accounts, currency control and the CFC rules are in the Russia hub.
Popular strategies that end badly
A UAE certificate while the family lives in Europe
Under art. 4 of Cabinet Decision No. 85 of 2022 a person present in the UAE for 90 days in twelve months becomes tax resident with a residence permit and either a permanent place of residence or employment or business there, while European residence rests on 183 days and the centre of vital interests — in Spain, Article 9 of Ley 35/2006. A family, a home and children's schooling in Europe outweigh the Emirati certificate, and DAC7 and CRS data keep flowing to the country of actual life while the address stays stale. The result is a dual-residence dispute in which a 90-day certificate makes weak evidence.
Fan tokens "as crowdfunding"
The Howey test looks for an investment of money with an expectation of profit from the efforts of others: fan tokens with growth promises and a secondary market may be found to be securities, and promoting someone else's token without disclosing the payment is Section 17(b) — the Kardashian scenario. Sanctions and defence lines are in celebrity promo liability.
Every contract in the manager's name
A management company that holds the brand deals, the catalogue and the trade marks leaves the author with no assets on a break-up: the income legally belongs to someone else's firm, and the rights have to be bought back. The working scheme keeps the image rights and the catalogue with the author or their holdco, with an agency fee for the manager under contract; the structures are in creator holdco, image rights and talent routes.
The summary table ties the standard tasks to the cluster's deep dives and their key figures.
| Task | What to read | Key figure or rule |
|---|---|---|
| Cost the platform withholding | Platform withholding | 30% of the US share; up to 24% without a form; W‑8BEN — 3 years |
| See what the tax authorities see | DAC7, MRDP, 1099-K and CESOP | services — no threshold; 1099-K — $20,000 and 200 transactions; CESOP — 25+ payments a quarter |
| Test a personal company | PSC and IR35 | Chapters 8 and 10 ITEPA 2003; offset from 06.04.2024 |
| Capitalise the catalogue and brands | Creator holdco | § 1221(a)(3) IRC: the author's own catalogue gets no capital gain |
| Structure the image rights | Image rights, publicity and AI | the image regime differs by country |
| Choose a base country | Creator relocation | Dubai 0% PIT / 9% CT; Spain 24% on employment income up to €600,000, closed to the self-employed; Kazakhstan 4% from 2026 |
| Assemble the Emirati circuit | The UAE hub | Creators HQ, 4–10 week cycle; Golden Visa up to 10 years |
| Obtain a US status | O-1B | 3 of the 6 criteria in 8 CFR 214.2(o)(3)(iv); premium $2,965 from 01.03.2026 |
| Obtain a UK status | Global Talent | Arts Council England endorsement; up to 5 years; settlement for leaders after 3 |
| Price the promo risk | Influencer regulation, celebrity promo liability | 16 CFR Part 255; Section 17(b): Kardashian's $1.26m |
| Close the Russian circuit | Regulating the infobusiness, the Russia hub | pages above 10,000 users; erid; VAT under the simplified regime above RUB 20 million |
| Count a touring year | Tax residence on tour | the country of performance and the day count |
| Price the exit | Exit tax | Germany — § 6 AStG, seven-year instalments |
The table works as an annual review checklist: a change in any row is a reason to open the matching deep dive.
A creator's year is counted in three passes. First, the streams: platform revenue, brand contracts, IP royalties, donations and tokens, each with its own tax character and its own withholding agent. Second, the base and the structure: country and visa, then individual, PSC or holdco, with the image rights kept by the author. Third, transparency and promos: DAC7 and MRDP with no threshold for services, CESOP from 25 payments a quarter, ad disclosure under 16 CFR 255. A structure built before the streams and the base have been counted usually costs more than having none.
Q/A
Where tax arises and who sees it
Which article to start with if all the income is platform income?
Two steps: the summary table of this hub and platform withholding. First count the US share of the audience and the character of the income — royalties or services — then choose a base with a working treaty and a feasible visa. Before those steps, country deep dives answer "how much", while the decision turns on "why".
Does moving to the UAE settle the tax question entirely?
No. Personal income tax is indeed zero, yet the UAE has no US tax treaty: the 30% on the American revenue segment stays, with nothing to credit it against. A local set of obligations is added on top: media licensing, and 9% corporate tax for an individual whose business turnover exceeds AED 1 million. The circuits are in the UAE hub and UAE tax residency.
Does the tax authority see income if the platform and the account are abroad?
Yes. DAC7 and MRDP transmit amounts for services with no minimum threshold, CESOP counts cross-border payments above 25 a quarter, and 1099-K covers the American segment — the full reporting map. For Russian residents, the duties on foreign accounts and the CFC rules apply regardless of any exchange — see the Russia hub.
Income character, companies and rights
Are donations gifts that carry no tax?
The characterisation depends on regularity and on what is given in return. A one-off transfer from a private person does pass as an untaxed gift in many systems, while regular donations for streams and content are treated by tax authorities as income from an activity: the IRS files them under the gig economy, payment providers surface them in CESOP, platforms in DAC7. The subscription-platform mechanics are in OnlyFans taxes.
When is it time to think about a company and a holdco?
When the income stops being advertising revenue alone: a team, a catalogue, product brands, capital transactions. Before that, a personal company more often creates reclassification risk than savings — the IR35 lessons. Capitalising the catalogue, with the § 1221(a)(3) trap, is in creator holdco; where the owner's home country has such rules (Russia among them), a foreign structure of this kind can become a CFC.
Who should own the image rights — the author or the company?
The base rule: the catalogue, the trade marks and the image rights are registered to the author or a holdco under the author's control, the operating company takes a licence priced at arm's length, and the manager holds agency powers without ownership. Transferring rights to a management firm means losing the asset when the relationship ends. The structures and licence pricing are in image rights and creator holdco.
Choosing a base regime
Which special regimes are actually open to a creator who invoices as a self-employed person?
The fourth column of the regime matrix answers it. Spain's Beckham regime reaches employment income and a director relationship, not an economic activity; Portugal's IFICI is open to category B income but content creation is not on the qualifying-activity list; the Cypriot 50% relief is an employment-income relief. The regimes drafted for individuals carrying on their own activity are Turkey's content-producer exemption under mükerrer art. 20/B GVK, Italy's forfettario, Georgian small business status, Serbian paušal, the Kazakh simplified declaration and the Armenian micro-business regime. The UAE and the UK FIG regime are status-neutral.
Why can a 1% regime beat a 0% one?
Because the personal rate is only the second number. Copyright royalties from the American audience are taxed at source before anything reaches the base country, and the rate depends on whether a treaty exists: 0% for Georgia and Armenia under the 1973 treaty and for Italy, Spain, Cyprus and the UK, 10% for Turkey, Portugal and Kazakhstan, 30% where there is no treaty at all — the UAE, Andorra and Serbia. On a mix where the United States is half the audience, the difference between 30% and 0% at source dwarfs the difference between a 1% and a 4% turnover rate.
What happens when revenue grows through the ceiling of a turnover regime?
The regime changes, not the rate. Georgia taxes turnover above GEL 500,000 at 3%; Italy's forfettario ends above €85,000; Turkey's art. 20/B exemption lapses above the fourth bracket of art. 103 GVK; the Kazakh simplified declaration has a 600,000 MRP ceiling. The change usually lands mid-year, with the activity already registered under a code the successor regime treats differently, which is why a base is chosen for the revenue two years out rather than this year's.