Taxation of Instagram Influencers

Abstract

This scientific article discusses issues related to the taxation of Instagram influencers. Its main objective is to define how the influencers' incomes should be taxed. To achieve this primary purpose, the partial objective is defined to give the list of (legal) cooperation contracts between the marketers and influencers. The hypothesis that there is no need to adopt new specific tax law norms to tax influ-encers' incomes properly, at least in developed countries, was confirmed. All jurisdictions are taxing influencers' incomes. It is always necessary to focus on the content of the relationship generating influencer's income, as the principle of priority of content over form must be used. The tax liability is influenced only by the tax base. The tax rate and other structural components of the tax remain the same for different types of incomes. Generally, it is always better for the influencer to have a trading license (to be a businessman) than tax his/her incomes as incomes from copyright. Incomes from dependent activities based on labour law contract or occasional incomes are not probable for a typical influencer, and still, the taxation in this way is not really favourable. The novelty of the presented research lies in the fact that no scientific articles deal with the covered issues published so far. The author believes that the article has a cognitive value for both science and practice.

Full text

Studia Iuridica Lublinensia vol. XXX, 2, 2021
DOI: 10.17951/sil.2021.30.2.339-356
Articles
Michal Radvan
Masaryk University, Czech Republic
ORCID: 0000-0002-9858-4555
michal.radvan@law.muni.cz
Taxation of Instagram Inuencers
Opodatkowanie inuencerów korzystających z Instagrama
ABSTRACT
This scientic article discusses issues related to the taxation of Instagram inuencers. Its main
objective is to dene how the inuencers’ incomes should be taxed. To achieve this primary purpose,
the partial objective is dened to give the list of (legal) cooperation contracts between the marketers
and inuencers. The hypothesis that there is no need to adopt new specic tax law norms to tax inu-
encers’ incomes properly, at least in developed countries, was conrmed. All jurisdictions are taxing
inuencers’ incomes. It is always necessary to focus on the content of the relationship generating
inuencer’s income, as the principle of priority of content over form must be used. The tax liability
is inuenced only by the tax base. The tax rate and other structural components of the tax remain the
same for different types of incomes. Generally, it is always better for the inuencer to have a trading
license (to be a businessman) than tax his/her incomes as incomes from copyright. Incomes from
dependent activities based on labour law contract or occasional incomes are not probable for a typical
inuencer, and still, the taxation in this way is not really favourable. The novelty of the presented
research lies in the fact that no scientic articles deal with the covered issues published so far. The
author believes that the article has a cognitive value for both science and practice.
Keywords: tax law; taxation; copyright; income; inuencer; Instagram
CORRESPONDENCE ADDRESS: Michal Radvan, Ph.D., Associate Professor, Masaryk
University, Faculty of Law, Veveří 158/70, 611 80 Brno, Czech Republic.
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INTRODUCTION
Social media play a more and more crucial role in many aspects of our every-
day life. At the very beginning, social media were designed primarily for individu-
als willing to share their feelings, ideas, pictures, videos, etc., with their friends. As
the number of people using social networks was growing, it occurred as a perfect
tool for both commercial companies and non-business equities to share information
about their products and services. Nowadays, it is almost impossible to imagine
a political party, public university, local businessman, or multi-national company
without its proles on Facebook, Instagram, Twitter, YouTube, LinkedIn, etc. The
ways social networks are to be used and how to use them in the most effective ways
are very different, depending on the type of entity, its aims and intentions. While
political parties and politicians want to inform possible voters on their programme
to get more votes in elections, universities attract students to study at the school,
informing students and staff about the news and presenting information to alumni
hoping to provide the school with nance.
For businesses, social media are crucial in the area of marketing. Still, a lot
of money is spent on traditional marketing on social networks, i.e., the compa-
ny presents its products, services o brand itself. However, the customers may
become apathetic to these advertising messages. Nevertheless, there is another
opportunity for marketers: they may use inuencers for promotion. The inuen-
cers are usually not directly connected with the marketers; at least the customers
believe so. As well, the customers may follow favourite inuencers; they have
condence in their experience and opinions. They trust that the social media
celebrities are using the best product, buying in the best shops, and having style
to be followed.
This article discusses issues related to inuencers. However, it is impossible
to cover all related topics such as marketing, management, psychology, sociology,
etc. It is impossible to deal with all social networks. That is why only Instagram is
being used as it is one of the two most popular platforms marketers are planning
to use for inuencer marketing and the fastest growing social network. The article
aims at the legal area, especially the tax law. The main objective of the contribution
is to dene how the inuencers’ incomes should be taxed. To achieve this primary
purpose, the partial objective is dened to give the list of (legal) cooperation con-
tracts between the marketers and inuencers. The author intends to demonstrate
the inuencers’ incomes must be taxed as any other income. The hypothesis to be
conrmed or disproved is that there is no need to adopt new specic tax law norms
to tax inuencers’ incomes properly. The article does not deal with international
aspects of inuencers’ taxation. The novelty of the presented research lies in the
fact that no scientic articles deal with the covered issues published so far. There
are, of course, scientic articles dealing with the Instagram inuencers from the
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Taxation of Instagram Inuencers 341
marketing,1 technical2 or psychological and sociological3 perspectives. The only
article focused on Instagram from the national tax law viewpoints by S. Şekeroğlu
and S. Bilgin4 is dealing with Turkish law. S. Kostikidis5 and D. Molenaar and
H. Grams,
6
in response, then concerns on international tax law. The author believes
that the article has a cognitive value for both science and practice.
The article has been divided into three substantive parts. The rst one introduces
Instagram as an important marketing tool and brings several statistics to prove this
statement. The second one describes the ways how the cooperation between the
marketers and the inuencers starts and takes place in practice and what are the legal
relations between them. It is necessary to analyse existing cooperation models as they
are essential for the third part dealing with the taxation issues. In fact, three possible
ways how to tax inuencers’ incomes are possible: to tax them as incomes from
dependent activities or incomes from independent (business) activities including in-
comes from intellectual property rights (copyrights) or occasional (irregular) incomes.
METHODOLOGY
For this research, it is necessary to get adequate knowledge from practice to
know how the relationship between marketers and inuencers works. The author
has decided to hold a structured, guided interview with two inuencers to get in-
formation on how the initial contact between the marketer and inuencer is made,
what form of contract they conclude, what are the rights and obligations, etc. He also
got information on how to be in touch with the followers and how it inuences the
incomes of the inuencer. Based on this knowledge, it was possible to dene private
law relationships applicable to the relation between the marketers and inuencers.
After that, the classical research methods and techniques developed within the
framework of legal sciences were used. An important value of legal knowledge is
1 For example, see M. De Veirman, V. Cauberghe, L. Hudders, Marketing through Instagram
Inuencers: The Impact of Number of Followers and Product Divergence on Brand Attitude, “Inter-
national Journal of Advertising” 2017, vol. 36(5), pp. 798–828.
2 For example, see K. Cotter, Playing the Visibility Game: How Digital Inuencers and Algo-
rithms Negotiate Inuence on Instagram, “New Media and Society” 2019, vol. 21(4), pp. 895–913.
3 For example, see L.V. Casaló, C. Flavián, S. Ibáñez-Sánchez, Inuencers on Instagram: An-
tecedents and Consequences of Opinion Leadership, “Journal of Business Research“ 2020, vol. 117(9),
pp. 510–519.
4 S. Şekeroğlu, S. Bilgin, Inuencer Marketing and Taxation of Inuencer in Turkey, [in:] New
Trends in Social Sciences, eds. H. Özüdoğru, T. Çetin, H. Kara, Klaipeda 2019, pp. 125–134.
5
S. Kostikidis, Inuencer Income and Tax Treaties, “Bulletin for International Taxation” 2020,
vol. 74(6), pp. 359–376.
6 D. Molenaar, H. Grams, Inuencer Income and Tax Treaties, “Bulletin for International Tax-
ation” 2020, vol. 74(9), pp. 550–555.
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Michal Radvan
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determining the meaning of norms (rules of behaviour) contained in the legislation.
Therefore, the formal dogmatic method was used as a primal method. To analyse,
interpret and assess the existing tax legislation, it was necessary to apply the rules
of legal linguistic interpretation. Later on, it was possible to describe and systemize
tax law provisions applicable to the relationships between marketers and inuen-
cers. Partially, the comparative method was used to compare the legal regulation
of income taxation in individual countries. The synthesis of arguments allowed to
formulate the conclusions, conrm or disprove the hypothesis, and possibly offer
improvements for the de lege ferenda regulation.
RESEARCH AND DISCUSSION
1. Instagram as a marketing tool
Compared to the other social applications,7 Instagram does not have many active
users. S. Kemp8 states that Facebook, as the top social application, has 2.7 billion
monthly active users, while YouTube and WhatsApp have 2 billion and Facebook
Messenger and WeChat approx. 1.3 billion. The only other application with more
than 1 billion users is Instagram; Instagram’s advertising audience reached a total
of 1.16 billion people in October 2020. Most users come from the US, India, Bra-
zil, Indonesia, and Russia, while 88% of Turkish internet users aged 16–64 years
are using Instagram. The Instagram penetration by country is signicant in most
key markets: Spain and Italy 67%, Germany 63%, Russia 61%, US, Australia, and
Canada 56%, UK 53%, France 50%, and Japan 39%.
9
More than 63% of Instagram
users are people between 18–34 years.10 Their top interests are traveling, music,
food and drink, fashion, movies, health and tness, technology, cosmetics, sports,
and news.11
For business purposes, it is necessary to have followers: the other uses of
Instagram following the prole. More than half of Instagram users have less than
1,000 follower count. The important number of followers for marketers is 10,000
followers. This condition is met by 10% of Instagram users, while 0.5% has more
7
All statistics are taken from M. Iqbal, Instagram Revenue and Usage Statistics (2021),
24.05.2021, www.businessofapps.com/data/instagram-statistics [access: 16.04.2021].
8
S. Kemp, Digital 2020: October Global Statshot, 20.10.2020, https://datareportal.com/reports/
digital-2020-october-global-statshot [access: 16.04.2021].
9 M. Iqbal, op. cit.
10 S. Kemp, op. cit.
11 Facebook for Business, How to Take Your Instagram Content to the Next Level, 14.02.2019,
www.facebook.com/business/news/insights/how-to-take-your-instagram-content-to-the-next-
level?ref=FBB_ConnectWithNewAudiences [access: 16.04.2021].
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Taxation of Instagram Inuencers 343
than 500,000 followers.12 The most followed celebrities (inuencers) are sports-
men (Cristiano Ronaldo, Lionel Messi), singers (Ariana Grande, Selena Gomez,
Beyoncé, Justin Bieber), models (Kylie Jenner, Kim Kardashian West), and actors
(Dwayne Johnson), all with more than 150 million followers, while Cristiano
Ronaldo has 244 million followers.
13
The most followed brands are Instagram
(382 million followers), National Geographic, NASA, fashion companies (Nike,
Victoria’s Secret), and accounts connected with sport (Real Madrid, FC Barcelona,
UEFA Champion’s League, NBA).14
Seeing the most popular brands and inuencers, it is evident that the most
popular industry on Instagram is fashion: the percentage of total Instagram brand
interactions is almost 25%. The other important industries are e-commerce, beauty,
auto, retail, electronic, services, and sporting goods.
15
Instagram users ascribe
especially popularity, creativity, fun, relevance, and community focus as values to
brands on Instagram.16 As well, they expect entertaining, authentic, informative,
personally relevant, and inspiring content.17 The research shows that 79% of Ins-
tagram users search for more information after seeing products and/or services on
Instagram, 65% of them visit the brand website, and 46% make a purchase. On top
of that, 37% of Instagram users visit a retail store, 31% follow the brand account,
and 29% speak to someone else about the brand.18
All these statistics are excellent for marketers as Instagram marketing using
inuencers effectively focuses on the target customers and their shopping behaviour.
That is why 72% of brand representatives believe that inuencer marketing results
in higher quality leads and 66% of brands planned to increase their inuencer mar-
keting spend in 2020.19 Marketers can make USD 5.20 for every USD 1 invested
in inuencer marketing.20 More than half (55%) of marketers are planning to use
12 HubSpot, Instagram Engagement Report – What Your Company Needs to Know for 2020,
10.03.2021, https://cdn2.hubspot.net/hubfs/53/HubSpotMention_ebook_2020-FINAL-1.pdf [access:
19.04.2021].
13 Social Blade, Top 50 Instagram Business Accounts Sorted by Followers, https://socialblade.
com/instagram/top/50 [access: 19.04.2021].
14 Ibidem.
15 T. Bern, Social Media Trends Report: Key Insights From Q3 2020, www.socialbakers.com/
blog/social-media-trends-report-q3-2020 [access: 19.04.2021].
16 Facebook for Business, How Instagram Boosts Brands and Drives Sales, 6.02.2019, www.
facebook.com/business/news/insights/how-instagram-boosts-brands-and-drives-sales [access:
19.04.2021].
17 Facebook for Business, How to Take Your Instagram Content…
18 Facebook for Business, How Instagram Boosts Brands…
19 Inuencer Marketing Hub, The State of Inuencer Marketing 2020: Benchmark Report,
14.02.2021, https://inuencermarketinghub.com/inuencer-marketing-benchmark-report-2020 [ac-
cess: 19.04.2021].
20 Ibidem.
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Instagram for inuencer marketing in 2021. Only YouTube expects more marketers
(58%), while online advertising is planned by 43%, TV advertising by 29%, and
out-of-home advertising by 20% marketers willing to use inuencers. The other
social networks planned to use are TikTok (35%) or Twitch (20% of marketers).21
Compared to the other platforms, 18% of marketers believe Instagram offers the best
inuencer marketing return on investments (ROI), which is the same as YouTube
and only 3% less than online advertising.22 In the end, 39% of brands spend over
20% of their marketing budget on inuencer marketing.
Table 1. How much do brands spend on inuencer marketing?
Proportion of marketing budget Proportion of brands
< 10% 22%
10–20% 39%
20–30% 23%
30–40% 7%
40%+ 9%
Source: Inuencer Marketing Hub, The State of Inuencer Marketing 2020: Benchmark Report, 14.02.2021, https://
inuencermarketinghub.com/inuencer-marketing-benchmark-report-2020 [access: 19.04.2021].
More than half (51%) of brands work with less than 10 inuencers, while 5%
of brands cooperate with 100–1,000 inuencers and 3% of brands work with more
than 1,000 inuencers. Dwayne “The Rock” Johnson, who charges on average
USD 1,015,000 per post, is the most expensive celebrity.23 However, the number
of followers nor the price per post does not mean marketing effectiveness as the
effectiveness measures number of followers, interactions per followers, and posting
activity. That is why the most effective brand inuencers are generally unknown
persons having a very different number of followers and interactions.
Table 2. Most-effective brand inuencers in Q3 2020
Inuencer Followers Interactions
Mridul Sharma 98,600 1,247,300
Julie Ferrat 165,700 1,024,000
Pamela Pedroza 13,500 591,500
Kanaan Pitan 54,700 483,000
Lauren Kettering 843,900 8,077,800
Samira Ahmed 106,200 604,600
Source: T. Bern, Social Media Trends Report: Key Insights From Q3 2020, www.socialbakers.com/blog/social-me-
dia-trends-report-q3-2020 [access: 19.04.2021].
21 Takumi, Into the Mainstream: Inuencer Marketing in Society, https://takumi.com/whitepa-
per2020 [access: 19.04.2021].
22 Ibidem.
23
Hopper HW, Instagram Rich List 2020, 19.04.2021, www.hopperhq.com/blog/insta-
gram-rich-list [access: 19.04.2021].
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Taxation of Instagram Inuencers 345
The effectiveness depends as well on the promoted industry: while the health
care industry has on average 4.2 interactions per brand post, airlines have only 0.2
average interactions per brand post. In these circumstances, the top industries are
(besides health care) nance, telecommunications, and accommodations, while the
weakest are not only airlines but the sporting goods and car industry, too.24 The
brands most mentioned by Instagram inuencers are IDeal of Sweden, Walmart,
Pretty Little Thing, Question Nutrition, Michelob Ultra, and L’Oréal Paris.25
Companies – marketers are aware of the inuencers’ power in marketing. For
example, a total US and Canada inuencer spend by quarter has almost tripled in Q4
2019 to USD 434 million from USD 163 million in Q1 2018.26 The top ten brands
spent almost USD 112 million on inuencer marketing in the US and Canada in
2019.27 Instagram itself, as a strong marketing platform, increased its net advertising
revenue (after trafc acquisition costs paid to partner sites) from USD 1.61 billion
in 2016 to an estimated USD 15.65 billion in 2021.28 To conclude, inuencer mar-
keting seems to be one of the most essential marketing tools for marketers. Global
spend on inuencer marketing is predicted to be worth somewhere between USD
5 billion and USD 10 billion by 2020 and rising as high as USD 15 billion by 2022.
29
2. Models of cooperation between the marketers and the inuencers
The structured, guided interview with two inuencers allowed the author to get
information on how the initial contact between the marketer and inuencer is made,
what form of contract they conclude, what are the rights and obligations, etc. Both
inuencers are ladies between 25 and 30 years old. They are studying and working
at the same time. However, the rst one is running her own business with hygienic
products for women, while the second one is working in the law rm and works as
24
T. Bern, State of Inuencer Marketing Report: Effects of Coronavirus, www.socialbakers.
com/blog/inuencer-marketing-report [access: 19.04.2021].
25 Idem, Social Media Trends Report…
26 J. Ghatt, Report: Top Brands Spent $255M on Inuencers with Fake Engagement, 5.03.2020,
https://jenebaspeaks.com/2020/03/report-top-brands-spent-255m-on-inuencers-with-fake-en-
gagement [access: 19.04.2021].
27 A. McClendon, It’s estimated that Fashion Nova spent $40M on inuencer marketing last
year, 2.03.2020, https://twitter.com/faintex/status/1234272114808696834?ref_src=twsrc%5Etf-
w%7Ctwcamp%5Etweetembed%7Ctwterm%5E1234272114808696834%7Ctwgr%5E%7Ctwcon
%5Es1_&ref_url=https%3A%2F%2Fwww.complex.com%2Fstyle%2F2020%2F03%2Ffashion-no-
va-spent-40-million-dollars-inuencer-marketing-2019 [access: 19.04.2021].
28
B. Droesch, Instagram’s New Explore Ads Signal Potential Changes to Organic Reach,
9.07.2019, www.emarketer.com/content/instagrams-new-explore-ads-signal-potential-changes-to-or-
ganic-reach [access: 19.04.2021].
29 Mediakix, The Inuencer Marketing Trends to Know for 2021, 17.04.2021, https://mediakix.
com/inuencer-marketing-resources/inuencer-marketing-trends [access: 19.04.2021].
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Michal Radvan
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a fashion model. For both of them, the incomes from inuencing activities are only
supplementary. The rst lady had her small groups of customers who followed her
on Instagram mainly because of her main product. She decided to offer them other
more or less related products: mainly cosmetics and clothes. At the moment, she has
approx. 8,000 followers. Most of them are independent married ladies from the Czech
Republic with above-average incomes. The second interviewed inuencer posts main-
ly sexy pictures as she is using Instagram as a platform to offer herself as a model.
She has over 48,000 followers. However, these are primarily men from all over the
world who want to see her new posts and videos; they are not willing to buy any
products and services such as a gym or food supplements she is (rarely) promoting.
From the examples mentioned above, it is evident that the number of followers
is not essential for the incomes of the inuencer. More crucial is the “quality” and
activity of followers; they must be materially secured. They have to follow the
inuencer because of products or services she/he promotes and have to follow the
inuencer regularly, ideally every day. That might be the reason why the incomes
generated by both interviewed inuencers are almost the same.
Both inuencers gave the same examples of cooperation (private law relation-
ships applicable to the relation) between the inuencer and the marketer. They both
stated that it is not probable that there would be any labour law relationship between
the parties; however, they were not able to tell the reasons. In the author’s opinion,
the reason might be practical: the inuencer is relatively free on the marketer, she/
he does not have to follow the marketer’s commands. The cooperation might be
only one-time or irregular. The income taxes are generally higher for employees
than self-employed persons, and there are additional social and health contribu-
tions to be paid. On the other hand, there might be cases of inuencers employed
by marketers. For example, if the inuencer is working for the marketer for some
time in a different position, and while promoting his/her products and services
effectively, the working position is changed.
The most common type of cooperation between the inuencer and the mar-
keter is a barter: the marketer contacts the inuencer by email or via Instagram,
offering some products or services at a specic value (but free for the inuencer)
for testing. The products or services are very different, from clothes and cosmetics
to holidays. As well, the value might differ a lot; in the case of higher values (e.g.,
a car), the inuencer gets right to use it only for a certain time and she/he has to
return it back and is not allowed to keep it. A specic type of barter is a trip to an
interesting destination to see the presentation of new products, while the marketer
pays the travelling costs. The marketer species what she/he demands in return:
product or service review in the form of several stories, posts, etc. The marketer
often adds discount coupons for the customers (codes) to be connected to the post.
If the barter cooperation works well, the next step is the cooperation contract
– the marketing representation. The inuencer becomes the ambassador of the
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Taxation of Instagram Inuencers 347
brand. It means, e.g., that the marketer sends the clothes collection four times
a year at a higher value and asks for more posts with hashtags or phrases in return.
Sometimes, the inuencer has to send pictures with the products to the marketer,
who is free to use them in his marketing campaigns. The best ambassadors may
get additional products as gifts. However, the question is whether it is really a gift
when they boast of it on Instagram, mentioning the marketer.
The second interviewed inuencer mentioned an additional type of barter co-
operation typical for models. When she was photographed to promote a collection
of clothes for a nancial reward, she can keep it under the condition she uses some
pictures as posts on her Instagram.
As stated above, the marketer may give the inuencer a unique code to be
connected to the post serving as a discount voucher for customers. The code is
connected with the inuencer’s name and the inuencer gets additional money
every month as a share of the price (5–20%) for the customer. This practice is
called afliate marketing.30
The most popular inuencers are not interested in barters and they get direct
payments for their posts. As obvious from the text above, the worldwide known
celebrities get more than USD 1 million per post, while local superstars get USD
5,000 at maximum.
Sometimes, suppose the inuencer does not respond to the marketer’s offer
(especially in the case of celebrities). In that case, the marketer sends the product
(primarily cosmetics) to the inuencer without a previous contract. If the inuencer
does not make promotion and does not send the product back, the product might
be seen as a gift.
To conclude, besides rare labour law relationships, there are several possibilities
of civil law contracts between the marketer and the inuencer. It will probably be
an innominate contract, close to a contract of work, or specically the contract of
work. By a contract for work, the inuencer (contractor) undertakes to perform
work, at his/her own expense and risk, for the marketer (client), and the marketer
undertakes to take over the work and pay the price.
The other possibility is a license as many posts and stories result from human
creation, namely creation that falls under creative or artistic activity; the inuencer
is free to create and combine creative elements.31 The ndings of the Court of Jus-
tice of the European Union32 also stated that the author’s own intellectual creation
must bear the “seal of his/her personality”, and through individual decisions made
within the framework of creative freedom, the author can “imprint his personal
30 K. Kůdelíková, Skrytá reklama na sociálních sítích – diplomová práce, Brno 2020, p. 55.
31 P. Koukal, Autorské právo, public domain a lidská práva, Brno 2019, p. 82.
32 For example, Order of the Court (Third Chamber) of 7 March 2013, Eva-Maria Painer v.
Standard Verlags GmbH and Others (C-145/10).
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touch” on the created work. Therefore, the author must have creative freedom in
choosing the elements of the work and their processing (combination). From this
creative freedom, it is possible to infer the individuality of the work. For example,
in portrait photography, creative freedom in the sense of copyright may consist in
the choice of “composition, the position of the photographed person or lighting”.
When shooting a photographic portrait, the author may also “choose the framing,
angle of the image, or atmosphere created”. Through these individual creative de-
cisions, the author of the portrait photograph can imprint his “personal touch”.33 By
a license agreement, a licensor (author, inuencer) grants to a licensee (marketer)
an authorisation to exercise intellectual property rights (a license) within the stip-
ulated limited or unlimited extent, and a licensee undertakes to pay remuneration
to the licensor.
As stated above, if the inuencer receives the product and does not make a pro-
motion and does not send the product back, the product might be seen as a gift. By
a donation contract, a donor gratuitously transfers the right of ownership in a thing
or undertakes to transfer the thing into the ownership of the donee, and the donee
accepts the gift or offer.
For all types of contracts, it is not decisive whether the contracts are written
or oral.
Besides the private law regulation of inuencer marketing, it is necessary to
briey comment on public law regulation, namely hidden advertising.34 The Eu-
ropean backgrounds are set by the Unfair Commercial Practices Directive.35 The
rules are transposed into national law, especially to public law acts regulating the
advertisement and the protection of consumers, and indirectly to private law acts
dealing with unfair competition. According to these legal acts, trade practices are
always considered deceptive, if the seller is using editorial space in mass media
for paid propagation of its product or service and the consumer cannot from its
content, pictures or sound unequivocally distinguish, that it is a commercial. Hidden
advertising is prohibited by Instagram policies, too.36
33 P. Koukal, op. cit., p. 83.
34 For more on this topic, including case law, see K. Kůdelíková, op. cit.
35 Directive 2005/29/EC of the European Parliament and of the Council of 11 May 2005 concern-
ing unfair business-to-consumer commercial practices in the internal market and amending Council
Directive 84/450/EEC, Directives 97/7/EC, 98/27/EC and 2002/65/EC of the European Parliament
and of the Council and Regulation (EC) no. 2006/2004 of the European Parliament and of the Council
(OJ EU L 149/22, 11.06.2005).
36 Instagram, Instagram Branded Content. Facebook for Business, 26.04.2021, www.face-book.
com/business/help/523975231703117?id=466037930669828 [access: 26.04.2021].
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Taxation of Instagram Inuencers 349
3. Taxation of Instagram inuencers
No matter the post or video is marked as paid propagation or not, no matter what
is the form and type of agreement between the marketer and the inuencer, and no
matter what is the legal status of the inuencer (entrepreneur with a trading license
or non-business subject without any license), any income of the inuencer is liable
to the (personal) income tax. In tax law, this principle is known as the principle of
priority of content over form. Moreover, the general anti-abuse rule (GAAR) must
be taken into account: for the purposes of calculating the tax liability, an arrange-
ment or a series of arrangements which, having been put into place for the main
purpose or one of the main purposes of obtaining a tax advantage that defeats the
object or purpose of the applicable tax law, are not genuine having regard to all
relevant facts and circumstances, shall be ignored. For these purposes, an arrange-
ment or a series thereof shall be regarded as non-genuine to the extent that they are
not put into place for valid commercial reasons which reect economic reality.37
Most of the personal income tax systems worldwide distinguish ve possible
types of income: incomes from dependent activities (labour law relationships),
incomes from independent (business) activities including incomes from intellectual
property rights (copyrights), capital incomes, rental incomes, and occasional (ir-
regular) incomes. For the inuencers’ incomes, capital incomes and rental incomes
are out of the question, while the other types of incomes shall be analyzed in detail.
All jurisdictions tax both monetary and non-monetary incomes, including barters
as used by the marketers and inuencers.
3.1. Taxation of incomes from dependent activities
Labour law relationships between the marketers and the inuencers are rare,
namely because the income taxes are generally higher for employees than self-em-
ployed persons, and there are additional social and health contributions to be paid
by the employer. However, it is necessary to investigate the concrete relationship
or concrete contract to decide how to tax the inuencer’s income: incomes from
a relationship where the taxpayer (inuencer, employee) must respect the payor’s
(paying agent’s – marketer’s, employer’s) commands in the course of execution
of work for the payor is taxable within the incomes from dependent activities. The
dependent work is work performed in relation to the superiority of the employer
and the subordination of the employee. The work is performed personally by the
employee for the employer, on behalf of the employer, during working hours de-
termined by the employer. The employer organizes and leads the work process and
37 Council Directive (EU) 2016/1164 of 12 July 2016 laying down rules against tax avoidance
practices that directly affect the functioning of the internal market (OJ EU L 193/1, 19/07/2016).
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Michal Radvan
350
bears the work’s production and economic risk.38 Based on these rules, especially
(but not only) marketing representation might be seen (if the circumstances are met)
as a similar relationship to the labour law relationship if the taxpayer must respect
the payor’s commands in the course of execution of work for the payor. Among
the features decisive for such a determination may be, e.g., preparation of posts
and videos by the marketer for the inuencer, determining the time of publication
of the post, setting hashtags associated with the post, etc.
While the tax rates are worldwide generally the same for the incomes from
dependent activities and other types of incomes, other structural components might
differ. Especially the construction of the tax base may signicantly inuence the tax
liability. In most countries, the brutto wage is used as a tax base. However, as the
employee pays social and health contributions, these contributions are deductible
from the tax base in several countries.39 Similarly to an entrepreneur, an employee
can have expenses incurred to generate, assure, and maintain the income, typically
travelling costs to the workplace, working clothes, technical equipment, etc. Some
countries (e.g., Austria, Germany, Poland) allow to deduct lump-sum expenses to
lower the tax base by a xed amount of money, by a percent, or in the combination
(by a percent up to the xed amount).
40
On the other hand, in the Czech Republic, the
partial tax base for the incomes from dependent activities was the super gross wage.
The super gross wage was dened as income from dependent activity increased
by sums of social security and health contributions (pension insurance premiums,
contribution to the state employment policy, sickness insurance premiums, and
health contribution) that the employer must pay according to special regu lations.
The social security and health contributions paid by the Czech employer are very
high – 33.8% (34% till the end of 2019) of the gross income.41
3.2. Taxation of incomes from independent activities
Most of the inuencers tax their incomes as incomes from independent (busi-
ness) activities. It is not crucial whether they have a trading license or not; black
business (without any ofcial permission or registration) is considered business
and incomes from black business are liable to tax. The key features for assessing
business activity are independence, consistency, performance of activities on own
38
L. Petríková, Závislá práca a pracovné právo – aktuálny stav, „Práce a mzdy“ 2019, vol. 14(7–
8), p. 21.
39
For example, in the Czech Republic until 2007. See M. Radvan, Czech Tax Law, Brno 2020, https://
science.law.muni.cz/knihy/monograe/Radvan_Czech_Tax_Law.pdf [access: 27.04.2021], p. 34.
40
European Commission, Taxes in Europe Database, https://ec.europa.eu/taxation_customs/
tedb/reneAdvSearch.html [access: 27.04.2021].
41 For more details, see M. Radvan, Taxation of Employment Income in the Czech Republic,
“Kwartalnik Prawa Podatkowego” 2018, vol. 20(1), pp. 23–35.
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Taxation of Instagram Inuencers 351
behalf, own account, and own responsibility (at own business risk) to achieve prot.
All inuencers generally follow these circumstances. Mostly, they are entirely free
on the marketer when preparing the post. Even if they have a duty to use a spe-
cic hashtag or publish the post on a specic date, these limitations are not the
obstacles to state that they are independent and their decisions are not inuenced
by the marketer.
Specic cooperation between the marketer and the inuencer might be only
one-time or irregular. To investigate the consistency of business activities, it is
necessary to examine the inuencers’ activity for all marketers. According to the
technical setting of Instagram concerning displaying posts, it is, in fact, necessary
to be active continuously to gain maximal reach. Denitely, when posting on In-
stagram, inuencers perform on their own behalf, own account, and own respon-
sibility. They certainly want to achieve prot; in this regard, it is not decisive if
they really make a prot.
As the activities of inuences fulll all conditions to dene them as business
activities, they should have a trading license. However, it is possible to be an in-
uencer and earn money without any trading license. There are two possibilities:
to get incomes from the pursuit of an independent profession or from copyright.
The independent profession is a term rarely known in tax law regulation. However,
it is used, e.g., by the Czech legislator for non-professional singers, painters, and
other artists so that they tax their occasional incomes as incomes from business
activities. It is not a systematic method of taxation. Moreover, the term “independ-
ent professions” is used in the Czech private law for a specic business without
the need for a trading license, such as regulated professions (attornies, notaries,
doctors, vets, etc.).
As stated above, most posts and stories result from human creation that falls
under creative or artistic activity. That is why it is possible to tax inuencers’ in-
comes as incomes from copyright.
For all types of independent activities, the income is to be dened as everything
the inuencer gets from the marketer, no matter if it is monetary or non-monetary
performance. If it is non-monetary performance (including “barters”), mostly the
value of products or services is set in the contract or in the communication between
the marketer and the inuencer. If it is not mentioned there, the value should be
set in any other way. The most common is the value of the goods and services as
announced by online shops.
The tax base for incomes from independent activities is created by the incomes
reduced by the expenses incurred to generate, assure, and maintain income. The
most common expenses are technical and graphic equipment (camera, phone,
laptop, software, etc.), internet connection costs, travelling costs, costs for the
webpage, marketing costs including payments to Instagram to increase the reach of
the post and post targeting, special courses, etc. In many countries (e.g., Slovenia,
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Michal Radvan
352
Slovakia, the Czech Republic, etc.
42
), taxpayers with limited incomes have the right
to claim lump-sum expenses instead of real expenses. While in most countries, the
lump-sum expenses are relatively low (10–30% of taxable incomes), in Slovakia,
they may reach up to 60%, and in Slovenia and the Czech Republic, up to 80% of
taxable incomes. Lump-sum expenses differ depending on the type of income. For
example, in the Czech Republic the inuencer with a trading license may claim
60%; however, if she/he gets incomes from the pursuit of an independent profession
or from copyright, it is only 40%.43
3.3. Taxation of occasional incomes
Inuencers receiving gifts (as unsolicited product, a gift to the ambassador,
unless required by contract) should tax the value of the gift as an occasional income;
the value is to be set according to the values as announced by (online) shops. The
same rule applies to any other occasional (irregular) income. The advantage is that
all states apply a certain non-taxable minimum for the occasional incomes (usually
between EUR 1,000–2,000). However, the tax base then includes the incomes re-
duced by expenses that can be submitted as having been incurred to (only) generate
such income, but not to assure and maintain the income, i.e., the expense must be
strictly connected with the income generated from concrete activity.
CONCLUSION
For businesses, social media are crucial in the area of marketing. Besides
traditional forms, marketers may use inuencers for promotion. Statistics prove
that inuencer marketing is a growing industry and Instagram has the ambition to
become the most popular social network for business promotions.
The article brings the list of legal cooperation contracts between marketers and
inuencers. The labour law relationships are rare, namely because of higher taxes
and contributions and the freedom of inuencers to prepare the post or video. There
are several possibilities of civil law contracts, mostly innominate contracts, close
to a contract of work, or specically contracts of work. Many posts and stories
result from human creation that falls under creative or artistic activity. That is why
a license agreement might be used. Rarely donation contracts are used. For all types
of contracts, it is not decisive whether the contract is written or oral.
Concerning income taxation of inuencers, from the international perspectives,
the tax rates may differ a lot: while in Bulgaria, the linear tax rate is 10%, in Austria,
Finland, and Sweden, the maximum rates in the progressive tax rates system reach
42 European Commission, op. cit.
43 M. Radvan, Czech Tax Law…, p. 35.
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Taxation of Instagram Inuencers 353
over 50%. All states offer some non-taxable minimums, either as item deductible
from the tax base or as a credit (tax relief). There might be different correction
components reecting the social status of the taxpayer (disability, children, mar-
riage, etc.).44 In every case, all jurisdictions are taxing inuencers’ incomes. From
the interstate perspective, it will always be necessary to focus on the content of the
relationship generating inuencer’s income, as the principle of priority of content
over form must be used, i.e., it is not decisive what is the form and type of agreement
between the marketer and the inuencer, or what is the legal status of the inuencer
(entrepreneur with a trading license or non-business subject without any license).
Inuencers’ incomes might be taxes as incomes from dependent activities if the
taxpayer (inuencer, employee) must respect the payor’s (paying agent’s – mar-
keter’s, employer’s) commands in the course of execution of work for the payor.
Among the features decisive for such a determination may be, e.g., preparation of
posts and videos by the marketer for the inuencer, determining the time of publi-
cation of the post, setting hashtags associated with the post, etc. The tax liability is
inuenced mainly by the construction of the tax base. In most countries, the brutto
wage is used as a tax base. In several countries, social and health contributions
or lump-sum expenses are deductible from the tax base. On the other hand, in the
Czech Republic the partial tax base for the incomes from dependent activities was
the super gross wage – the brutto wage increased by sums of social secu rity and
health contributions paid by the employer.
Most of the inuencers tax their incomes as incomes from independent (busi-
ness) activities. The key features for assessing business activity are independence,
consistency, performance of activities on own behalf, own account, and own re-
sponsibility (at own business risk) to achieve prot. As the activities of inuences
fulll all conditions to dene them as business activities, they should have a trading
license. However, it is possible to be an inuencer and earn money without any
trading license. There are two possibilities: to get incomes from the pursuit of an
independent profession or from copyright. The income is to be dened as everything
the inuencer gets from the marketer, no matter if it is monetary or non-monetary
performance, i.e., including barters as used by the marketers and the inuencers.
The tax base for incomes from independent activities is created by the incomes
reduced by the expenses incurred to generate, assure, and maintain income. The
most common expenses are technical and graphic equipment, internet connection
costs, travelling costs, costs for the webpage, marketing costs, etc. In many coun-
tries, taxpayers with limited incomes have the right to claim lump-sum expenses
instead of real expenses. The percent differs depending on jurisdiction and the type
of income (trading license, independent profession, copyright).
44 European Commission, op. cit.
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Michal Radvan
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Gifts as unsolicited products, gifts to the ambassador, unless required by con-
tract, and other occasional (irregular) incomes should be taxed as an occasional
income. Most jurisdictions offer a certain non-taxable minimum. The tax base often
includes the incomes reduced by expenses that can be submitted as having been
incurred to (only) generate such income, but not to assure and maintain the income.
As evident, the tax liability is inuenced only by the tax base. The tax rate
and other structural components of the tax remain the same for different types of
incomes. Generally, it is always better for the inuencer to have a trading license
(to be a businessman) than tax his/her incomes as incomes from copyright. Incomes
from dependent activities based on labour law contract or occasional incomes are
not probable for a typical inuencer, and still, the taxation in this way is not really
favourable. Even if some authors45 argue that it is necessary to amend the national
legal regulation to make the inuencers’ income taxation more transparent and fair,
de lege lata regulation, at least in all developed countries, is in the author’s opinion
convenient. There is no need to adopt new specic tax law norms to tax inuencers’
incomes properly. The hypothesis stated in the introduction is conrmed. However,
it must be stated that it is relatively difcult for the tax ofces to identify both the
inuencers with the tax duties and their taxable incomes. In every case, the tax-
payers have a duty to le the tax return and pay the tax under the self-application
principle. However, most of them do not do this and the activity of the tax ofce
should follow. To nd the taxpayers, it is possible to ask Instagram to pass the list
of inuencers with marketing activities using the tools in tax procedural codes. To
identify the incomes, it would be necessary to go through the Instagram prole and
contact the marketers to present the contracts or invoices.
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ABSTRAKT
W niniejszym artykule omówiono kwestie związane z opodatkowaniem inuencerów korzy-
stających z serwisu społecznościowego Instagram. Głównym celem było ustalenie sposobu, w jaki
należy opodatkować dochody inuencerów. Celem pośrednim dla osiągnięcia tego podstawowego
celu było sporządzenie listy umów o współpracy pomiędzy specjalistami od marketingu a inuen-
cerami. Potwierdzono hipotezę o braku potrzeby uchwalania nowych norm prawa podatkowego
dla prawidłowego opodatkowania dochodów inuencerów, przynajmniej w krajach rozwiniętych.
Wszystkie systemy prawne opodatkowują dochody inuencerów. Trzeba zawsze koncentrować się na
treści stosunku generującego dochód inuencera, gdyż należy stosować zasadę pierwszeństwa treści
nad formą. Należność podatkowa wynika jedynie z podstawy opodatkowania. Stawka podatku i inne
elementy składowe podatku są takie same dla różnych rodzajów dochodu. Co do zasady rejestracja
działalności gospodarczej jest dla inuencera zawsze lepszym rozwiązaniem niż opodatkowanie
dochodów z praw autorskich. Dochody z niezależnej działalności w oparciu o umowę o pracę lub
dochody okazjonalne są dość rzadkie dla typowego inuencera, a opodatkowanie w ten sposób nie
jest w istocie korzystne. Nowatorski charakter przedstawionych badań polega na tym, że dotychczas
w żadnych opublikowanych artykułach naukowych nie poruszono przedmiotowej tematyki. W opinii
autora artykuł ma wartość poznawczą, zarówno naukową, jak i praktyczną.
Słowa kluczowe: prawo podatkowe; opodatkowanie; prawa autorskie; dochód; inuencer;
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Pobrane z czasopisma Studia Iuridica Lublinensia http://studiaiuridica.umcs.pl
Data: 01/07/2021 21:51:18
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