The Netherlands: CFK bridging scheme and international taxation

The Netherlands has a special bridging scheme forprofessional football players and cyclists, the CFK 2.

During their active career they pay contributions into the CFK fund, from which they will receive the benefits directly after their career, paid as an annuity over a period of time. The purpose of the CFK fund is to give football players or cyclists time to adjust to a life without active sports and to build up a new career.

The contributions during the career can be deducted from the taxable salary, which means that the benefits after the career are taxable income. But it might be that the football player or cyclist has become a resident of another state than The Netherlands when the benefits are paid and then the question arises which state has the right to tax the income.