Jessica JohnsonToday, September 27, 2026, Ricky Martin and Brazilian DJ Pedro Sampaio take the stage at Rio de Janeiro's Maracanã Stadium for the halftime show of the first-ever NFL regular-season game played in Brazil — the Baltimore Ravens versus the Dallas Cowboys. Behind the spectacle of a 13-minute performance seen by millions, a complex web of cross-border entertainment contracts makes the whole thing legally and financially viable. For any US-based artist thinking about international work, this moment is worth studying closely.
The NFL's 2026 international slate is a record-breaker: nine games across seven countries and four continents, from Melbourne to Madrid, London to Mexico City. Each host city adds a new layer of legal complexity for American performers who step into the halftime spotlight. What applies to Ricky Martin — at a smaller scale — applies to any US musician, speaker, or entertainer who accepts an international booking.
Why the NFL's Global Push Changes the Math for US Artists
The scale of the 2026 international program is unprecedented. American Express is presenting all seven halftime shows at international games this season, creating three-party commercial arrangements between the league, a corporate sponsor, and the artists. Each party has distinct interests. Each contract covers performance fees, IP licensing, broadcast rights, technical riders, and liability allocation across multiple legal jurisdictions.
For the Rio game, broadcast rights were sold to Globo, with the performance airing on GETV and sportv in Brazil. That broadcast deal exists in a separate contractual lane from Ricky Martin's performance agreement — but if the artist's contract doesn't explicitly address how halftime footage can be used, replayed, or licensed downstream, the artist may have little leverage over how their performance travels.
This is the gap that entertainment lawyers exist to close. And it's a gap that appears in contracts at every fee level, not just for globally recognized artists.
What Entertainment Lawyers Review Before an International Performance
When a US artist performs abroad, their standard domestic contract template rarely survives contact with a foreign legal system. Brazil, like most of continental Europe and Latin America, operates under a civil law framework — meaning IP rights, employment classifications, and contract enforcement work differently than under US common law.
Five issues dominate international performance contract reviews:
Performance fee structure and currency risk. Is the fee gross or net? If the destination country withholds tax on foreign performers, does the contract specify who bears that cost? Exchange rate fluctuations on a dollar-denominated fee paid weeks after the event can meaningfully reduce what the artist actually receives.
Local tax withholding obligations. Brazil applies a 25% Withholding Income Tax (IRRF) on performance income paid to foreign non-residents, according to the IRS guidance on artists, athletes and entertainers. Because the US and Brazil do not have a full bilateral income tax treaty (unlike the US-Germany or US-UK arrangements), US artists performing in Brazil face a real double-taxation exposure that only careful contract structuring can mitigate.
IP and broadcast licensing. Brazilian intellectual property enforcement is handled through the Brazilian National Institute of Industrial Property (INPI), not through US copyright law. An artist performing at a Brazilian venue holds rights under Brazilian law, not American law — and those rights must be explicitly asserted in the contract to be protected when broadcast partners enter the picture.
Technical rider compliance under local labor law. A 40-person touring crew working at a Brazilian stadium is subject to Brazilian labor classifications, union equivalents, and local permitting rules. Riders drafted to US venue standards may create compliance issues that fall on the artist's production company if not addressed before signing.
Indemnification and force majeure. Brazilian courts apply the concept of caso fortuito (fortuitous event) to contract disruptions — a broader standard than the narrow force majeure definitions often embedded in US-drafted agreements. An artist relying solely on their standard domestic force majeure language may find it unenforceable in a Brazilian dispute.
As previously noted in our coverage of image rights negotiations in the entertainment industry, the gap between what artists assume their contracts cover and what is actually enforceable in foreign jurisdictions has created costly disputes for performers at every career level.
Concrete Case: How a Missing Clause Costs One Performer $95,000
Consider a composite scenario that entertainment lawyers report seeing regularly in cross-border deals:
A US-based musician — call them "Alex" — accepts a $200,000 headline slot at an international sports event in Brazil. Their manager sends a standard English-language contract drafted for US venues. No cross-border review is completed. The event organizer, a Brazilian promoter, signs and wire-transfers an advance.
Here is where the math breaks down:
Brazilian withholding tax: Brazil applies a 25% IRRF on the $200,000 fee for a foreign non-resident performer. That's $50,000 withheld at source before Alex receives anything. The contract contained no gross-up clause requiring the promoter to cover withholding — so Alex nets $150,000 instead of $200,000 and still owes US federal income tax on the full $200,000.
Broadcast rights omission: The event organizer licenses the performance footage to a Brazilian streaming platform for $45,000. Alex's contract was silent on broadcast licensing. Under Brazilian civil law, the organizer had sufficient contractual latitude to negotiate that licensing deal without Alex's involvement. Alex sees none of that $45,000.
Force majeure mismatch: A logistics disruption delays load-in by 18 hours, threatening the show. Alex's team attempts to invoke their standard US force majeure clause and renegotiate the schedule. The Brazilian promoter's attorneys argue the caso fortuito threshold has not been met under Brazilian law. Alex performs under pressure or forfeits the remaining 50% of their fee.
If Alex had retained an international entertainment lawyer before signing:
- A gross-up clause would have protected the full $200,000 net
- An explicit broadcast licensing provision would have secured 15–20% of downstream streaming revenue (roughly $6,750–$9,000 on a $45,000 deal)
- A Brazilian-law-aligned force majeure clause would have provided a genuine exit mechanism
Estimated cost of legal review at this fee level: $4,000–$10,000. Combined value protected: approximately $95,000+ in fee exposure, lost revenue, and avoided litigation risk.
The IRS also notes that US artists can reduce double-taxation exposure through treaty mechanisms where applicable — but only if their legal structure is correctly documented before the performance date. Retroactive fixes rarely work.
What the NFL Rio Game Signals for the International Entertainment Economy
Ricky Martin's Maracanã performance is not just a headline moment. It reflects a structural shift in how global entertainment is being distributed. The NFL's international expansion in 2026 is a signal that international performance economics are growing fast — and that more US artists at more career levels will be offered cross-border bookings in the years ahead.
The legal complexity doesn't scale down proportionally with the fee. A $30,000 keynote engagement in Germany or a $50,000 festival headline slot in Mexico carries the same five contract risk areas as a major halftime show. The difference is that smaller artists often skip the legal review because the cost feels disproportionate — not realizing that on a $30,000 international booking, an unreviewed withholding clause can quietly consume $7,500 to $12,000 before the artist ever receives payment.
Music contract structures are already complex in a domestic context. Add a foreign jurisdiction and a corporate presenter like American Express into the mix, and the number of moving parts multiplies quickly.
What to Do Before Your Next International Booking
If you are a US-based performer or creative professional considering any international engagement — music, speaking, entertainment, or production — here is the minimum legal review checklist before you sign:
- Gross vs. net fee: Does the contract protect your fee against foreign withholding tax?
- Broadcast and streaming rights: Are downstream licensing revenues explicitly addressed and allocated?
- Force majeure definition: Is the clause aligned with the legal standard of the performance country?
- Rider and crew compliance: Does your production rider comply with local labor and permitting rules?
- Dispute jurisdiction: If something goes wrong, which country's courts resolve it — and under what law?
An entertainment lawyer with international practice experience can work through these five areas in a single contract review session. For most mid-level performers, it is the highest-ROI legal investment they can make before accepting any foreign booking.
Disclaimer: This article is for informational purposes only and does not constitute legal or tax advice. Consult a qualified entertainment lawyer or tax advisor for guidance specific to your situation.
ExpertZoom connects US performers and creative professionals with entertainment lawyers experienced in cross-border agreements. Whether you are planning a first international tour date or reviewing a one-off high-value booking, a consultation before you sign is the step that matters most.
