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Model taxes: what is withheld abroad and what you declare at home

Model taxes explained: how Italy, Japan, the US, France, the UK and Germany withhold tax from foreign models, tax treaties, and what to declare at home.

Model taxes: what is withheld abroad and what you declare at home
Contents

In short

  • Models pay tax like anyone else who earns money. Most are self-employed, so nobody takes tax off for them at home: they set money aside and file a return.
  • When you work abroad, the local agency often withholds tax before it pays you: 30% in Italy, 20.42% in Japan, 30% in the US unless a treaty exemption is claimed on Form 8233.
  • France treats models as employees by law. The UK withholds 20% only on TV and online adverts and on public catwalk shows with paid tickets, never on still photo shoots.
  • Tax treaties stop you paying twice, but only if you keep proof of what was withheld. Ask for a tax certificate after every trip.
  • Since 2014 the OECD Commentary says the "artistes" article of tax treaties does not cover a model presenting clothes at a show or a photo shoot. That can matter when you claim money back.

Most models think about tax twice: when a statement arrives with a line called "tax" on it, and when the first annual return is due. By then the money is often spent. How your work is set up and taxed decides how much of each fee you keep, so it is worth understanding before the first trip.

This guide explains model taxes for anyone who works across borders: what foreign markets withhold from non-resident models, how tax treaties work, which documents to keep, and how a Lithuanian tax resident declares foreign income in 2026. We wrote it with the experience of Supermodels, the Vilnius agency that sends models to Milan, Paris, London, New York and Asia, and with rules taken from tax authorities. It is a general picture: before big decisions, speak to an accountant in your country. How a fee turns into take-home pay is covered in our guide how much do models make.

Do models pay taxes?

Yes. A model's fees are taxable income wherever the model lives. What differs is who pays the tax and when.

  • Self-employed model at home. This is the usual set-up. You invoice the agency or client, receive the gross fee and pay income tax and social contributions yourself, usually once a year.
  • Employee. In some countries, France above all, the model is an employee of the agency for each booking. Tax and social charges are taken from the pay slip.
  • Non-resident working abroad. The foreign agency or client often withholds tax at source before paying you. That tax shows on your model statement.

Because the money passes through agencies, many models never see a tax form until something goes wrong. Keep your own record of every job and every deduction from the start.

Withholding tax abroad, country by country

When you work in a market where you are not tax resident, local law usually takes its share first. These are the rules set by each country's tax authority.

CountryWhat is withheld from a non-resident modelTreaty with Lithuania in force since
Italy30% final withholding on self-employed fees, including occasional work, for services performed in Italy2000
Japan20.42% (20% plus the reconstruction surtax) on pay for work or personal services in Japan2019
United States30% on non-employee pay, unless a lower treaty rate or an exemption is claimed on Form 82332000
FranceModels are presumed employees. Non-residents' salaries in 2026: 0% up to €17,275 a year, 12% up to €50,112, 20% above1997
United Kingdom20% under the foreign entertainers rules, only for TV or online adverts and catwalk events with an entrance fee2002
Germany15% under § 50a EStG for performances, which include specially choreographed fashion shows1999
ChinaProgressive, from 3% up to 45% above 80,000 CNY a month1997

United States: Form 8233 and the treaty

The US withholds 30% from non-resident aliens' non-employee pay unless a treaty says otherwise. A treaty exemption for personal services is claimed on Form 8233, not on the W-8BEN. Under the US–Lithuania treaty, independent personal services (Article 14) are taxed only in the country of residence unless the person has a fixed base in the US. Staying more than 183 days in any twelve months counts as a fixed base. Entertainers (Article 17) can be taxed in the US unless their gross receipts for the year are $20,000 or less. In 1999 the IRS advised that a model and actor promoting products was not an "entertainer" for treaty purposes, which supports Article 14 for print and fashion work. TV commercials may still fall under Article 17.

United Kingdom: when nothing is withheld

HMRC's guidance, updated in July 2026, is unusually precise. The foreign entertainers rules cover fees paid to models for appearances in TV or online adverts and for catwalk events where an entrance fee is charged, including payments for streaming or recording them. No tax is withheld on payments to models at still photographic shoots, or to catwalk models at an event that is not open to the public, even if it is filmed or streamed.

France: the model is an employee

The French Labour Code presumes that any contract to hire a model for pay is an employment contract. The agency employs the model for the booking and runs French payroll. Non-residents' salaries fall under the 2026 withholding scale shown in the table. The separate 15% withholding for artistes does not list models, so a model is most likely taxed on the salary scale.

Are models "entertainers" under tax treaties?

Tax treaties have a special article for artistes and sportspeople, which lets the country where they perform tax their fees. Since 2014 the OECD Commentary on that article says it does not extend to "a model performing as such (e.g. a model presenting clothes during a fashion show or photo session) rather than as an entertainer". A few countries, Turkey among them, disagree.

Courts have reached similar views. In 2018 Italy's Supreme Court held that fees paid to non-resident models for a commercial shoot fall outside the artistes article and count as independent services, which Italy may tax only if the model has a fixed base there. The US IRS advice of 1999 points the same way.

In practice local withholding still happens first, because agencies follow domestic law. The treaty decides whether that tax can be reclaimed or credited at home. That takes paperwork and time, and the foreign agency and an accountant need to handle it together.

Model training with SupermodelsTry it in practice with an agency teamIn the model training we work on the walk, posing and working on camera, one to one or in a small group.About the trainingfrom €69

Documents to keep after every trip

  • The final statement from each agency, with every job, commission and deduction.
  • A certificate of the tax withheld, issued by the agency or the local tax office.
  • Pay slips, if you worked as an employee (France).
  • Your contracts and deal memos, with the fee and usage agreed.
  • Your own notes: dates, clients, hours and amounts.

Without proof of tax paid abroad, your home tax office may tax the same money again. Ask for the certificate before you leave the market: getting it later from another country is slow. How to read and check a statement is explained in how do models get paid.

Lithuanian tax residents in 2026

For models based in Lithuania, the usual route is individual activity registered with the tax authority (individuali veikla pagal pažymą). The business certificate (verslo liudijimas) is not available: the 2026 list of activities has no entry for models.

  • Income tax. From 2026 profit from individual activity is taxed at 20% with a credit. The effective rate is 5% up to €20,000 of profit and rises to 20% at €42,500. Above that, all income is added together and taxed at 20%, 25% or 32%.
  • Expenses. You can deduct documented costs or a flat 30% of income without receipts.
  • Social contributions. 12.52% pension and sickness insurance plus 6.98% health insurance, on 90% of taxable profit.
  • Example. A model who invoices €20,000 in a year, has no other income and takes the 30% deduction pays about €3,157 in total, roughly 16% of the gross.
  • Foreign income. All of it is declared in the annual return (GPM311). If the other country had the right to tax it under a treaty and did, Lithuania does not tax it again. If nothing was withheld abroad, Lithuanian tax is due. Since 2026 exempt foreign income still counts towards the annual total that sets your Lithuanian rate.
  • Copyright or performer contracts, sometimes used for TV commercials: income tax 15% up to 12 average wages a year for people without individual activity, and 19.5% social contributions, charged on 90% of the fee from 1 July 2026 (50% before).

Minors: who signs and where the money goes

In Lithuania parents sign contracts for a child under 14. A teenager aged 14 to 18 signs with a parent's consent but may freely use their own earnings. Tax rules are the same as for adults, and the agency or client usually handles the deduction.

Some markets protect minors' money by law. In New York, since the Child Model Act of 2013, 15% of a child model's gross earnings must go into a Child Performer Trust account. California's Coogan law also puts 15% of a minor's earnings into a blocked trust account. Parents should ask about these rules before a child's first trip, and read our guide to the modeling contract.

Practical tips

  • Register your self-employed activity before the first job, not after it.
  • Set aside 15% to 20% of every fee for tax.
  • Ask for tax certificates straight after each trip.
  • Keep statements, contracts and invoices for several years.
  • Choose an agency that shows every deduction. How to judge one is in how to choose a modeling agency.

Tax is one part of a model's finances. Which markets pay, how guarantee contracts in Asia work and how to plan a season so it does not end in debt are covered in the Supermodels Masterclass, an online course led by Jurgita Kiguolė, head of Supermodels. The course is in Lithuanian.

Supermodels Masterclass: markets, contracts and money (in Lithuanian)

FAQ

Do models pay taxes?

Yes. Most models are self-employed and pay income tax and social contributions in their home country. When they work abroad, the local agency often withholds tax before paying them.

How much tax is withheld from models abroad?

It depends on the country: 30% in Italy, 20.42% in Japan, 30% in the US unless a treaty exemption is claimed, 15% in Germany for choreographed shows, and in the UK 20% only on TV and online adverts and public paid catwalk events.

Will I pay tax twice on money earned abroad?

Not if a tax treaty applies and you keep proof of the foreign tax. Your home country then exempts the income or credits the tax paid abroad. Without a certificate you may be taxed again.

What can models deduct as expenses?

That depends on your country's rules. In Lithuania a self-employed model can deduct documented costs or a flat 30% of income with no receipts, which is often simpler because agencies already advance travel and housing.

Is a model an entertainer for tax purposes?

Since 2014 the OECD Commentary says a model presenting clothes at a show or photo session is not covered by the artistes article of tax treaties. Italy's Supreme Court and the US IRS have taken similar views, though local withholding still applies first.

Do child models have special money rules?

In New York and California 15% of a minor's gross modeling earnings must go into a trust account the child can use as an adult. In Lithuania parents sign for children under 14, and teenagers aged 14 to 18 control their own earnings.

Sources

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Jurgita editors
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The Jurgita desk has written about fashion, style, beauty and the modeling trade since 2010. It is led by editor-in-chief Jurgita Kiguolė, head of the Supermodels model agency.

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