14 hours ago, terraloon said:

Image rights have been a bone of contention for quite a while in the UK. Payment into players companies have been common place with their being corporation tax the main source of government taxation . Some individuals have never taken dividends but even when they have Class 1 Nic is not payable. The way in which image rights have to be treated for taxation purpose changes next year .

Are there limits to how much of a player's renumeration can be labelled "image-rights"? So for example, can a player repackage their salary such that a portion is paid as a usage fee for image rights? It's interesting in the PL context because the PL broadcasting deal is actually contingent on a set amount of player involvement for promotion, and of course all PL media is cut and used across social media etc. I can see why people would want it taxed as income, though.

14 hours ago, terraloon said:

When it comes to payments to third parties the simple fact that it wasn’t Chelsea that paid the amounts being detailed it was companies owned by RA which as we know, may not agree with, but know they shouldn’t be made so as consequence the club have to accept that under HMRC the responsibility for ensuring the payment didn’t have with it a tax liability and that’s why their is a settlement.

This is the part I don't quite understand. In the PL statement, the third-party entities are specified as 4 Abramovich companies registered in either British Virgin Islands or Panama and the transactions are reported to have happened completely off-shore. Under the PL and FA rules, any transaction even tangentially related to the transfer of a player is considered a "Club football-related matter" and its cost must be reported to the League for the assessment of PSR, even when that transaction occurs outside the UK. However, outside football, if the transaction occurs wholly outside the jurisdiction of the UK, I'm struggling to see why HMRC could have involvement - other than the fact that 3 of the companies are in BVI, and I suspect subject to extra scrutiny when paying UK entities in any event.

The exception might be the payments made to Arnesen and de Visser, who were direct employees of the club at the time. I presume that HMRC would need to have a view as to whether they should be subject to income or payroll tax?

14 hours ago, terraloon said:

As an aside I don’t know if you have commented on the FIFa changes re the requirement to sell release clauses in contracts from 1/1/27 but pretty much in line as we were thinking

Not yet in detail, but I'm glad FIFA took our advice! FIFA's hand was forced by UEFA in any case, as UEFA and the European players' unions reached an agreement to collectively bargain in 2025, releasing a statement that UEFA would adopt this regardless of FIFA's stance. The proposed agenda for bargaining includes mutual agreement on release clauses limited by the residual value of the contract.

The 5% commission for players earning under 150k p/a is a very interesting measure, because it actually leaves the player with a vested interest in facilitating a good transfer fee. I expect the player's union will also push for a similar commission for elite professionals, and clubs might agree on the same basis.

6 hours ago, SydneyChelsea said:

Are there limits to how much of a player's renumeration can be labelled "image-rights"? So for example, can a player repackage their salary such that a portion is paid as a usage fee for image rights? It's interesting in the PL context because the PL broadcasting deal is actually contingent on a set amount of player involvement for promotion, and of course all PL media is cut and used across social media etc. I can see why people would want it taxed as income, though.

This is the part I don't quite understand. In the PL statement, the third-party entities are specified as 4 Abramovich companies registered in either British Virgin Islands or Panama and the transactions are reported to have happened completely off-shore. Under the PL and FA rules, any transaction even tangentially related to the transfer of a player is considered a "Club football-related matter" and its cost must be reported to the League for the assessment of PSR, even when that transaction occurs outside the UK. However, outside football, if the transaction occurs wholly outside the jurisdiction of the UK, I'm struggling to see why HMRC could have involvement - other than the fact that 3 of the companies are in BVI, and I suspect subject to extra scrutiny when paying UK entities in any event.

The exception might be the payments made to Arnesen and de Visser, who were direct employees of the club at the time. I presume that HMRC would need to have a view as to whether they should be subject to income or payroll tax?

Not yet in detail, but I'm glad FIFA took our advice! FIFA's hand was forced by UEFA in any case, as UEFA and the European players' unions reached an agreement to collectively bargain in 2025, releasing a statement that UEFA would adopt this regardless of FIFA's stance. The proposed agenda for bargaining includes mutual agreement on release clauses limited by the residual value of the contract.

The 5% commission for players earning under 150k p/a is a very interesting measure, because it actually leaves the player with a vested interest in facilitating a good transfer fee. I expect the player's union will also push for a similar commission for elite professionals, and clubs might agree on the same basis.

At one point, HMRC was investigating the legitimacy of the figures in image rights contracts. In other words, had player X's image rights been exploited (or were capable of being exploited) to the level of the figure in the contract.

13 hours ago, The Rising Sun said:

Dan Levy wanted to cease all new senior concession season tickets. And to increase existing concession prices until they were full price. I seem to remember that we announced that concessions would remain, but that they were "under review" before the start of maybe last season.

Levy's justification was that it was financially unviable to have concessions!!

I remember Levy announcing that. Very poor from him and a terrible way to treat fans who've followed Spurs for many years and have probably spent a fortune following the club. Also forgetting that some seniors are reliant on state pensions and as we know going to football isn't cheap. Levy is like so many owners - past and present - who've become so obsessed with returns on investment that they've lost touch with the fans and the souls of clubs.

8 hours ago, SydneyChelsea said:

Are there limits to how much of a player's renumeration can be labelled "image-rights"? So for example, can a player repackage their salary such that a portion is paid as a usage fee for image rights? It's interesting in the PL context because the PL broadcasting deal is actually contingent on a set amount of player involvement for promotion, and of course all PL media is cut and used across social media etc. I can see why people would want it taxed as income, though.

This is the part I don't quite understand. In the PL statement, the third-party entities are specified as 4 Abramovich companies registered in either British Virgin Islands or Panama and the transactions are reported to have happened completely off-shore. Under the PL and FA rules, any transaction even tangentially related to the transfer of a player is considered a "Club football-related matter" and its cost must be reported to the League for the assessment of PSR, even when that transaction occurs outside the UK. However, outside football, if the transaction occurs wholly outside the jurisdiction of the UK, I'm struggling to see why HMRC could have involvement - other than the fact that 3 of the companies are in BVI, and I suspect subject to extra scrutiny when paying UK entities in any event.

The exception might be the payments made to Arnesen and de Visser, who were direct employees of the club at the time. I presume that HMRC would need to have a view as to whether they should be subject to income or payroll tax?

Not yet in detail, but I'm glad FIFA took our advice! FIFA's hand was forced by UEFA in any case, as UEFA and the European players' unions reached an agreement to collectively bargain in 2025, releasing a statement that UEFA would adopt this regardless of FIFA's stance. The proposed agenda for bargaining includes mutual agreement on release clauses limited by the residual value of the contract.

The 5% commission for players earning under 150k p/a is a very interesting measure, because it actually leaves the player with a vested interest in facilitating a good transfer fee. I expect the player's union will also push for a similar commission for elite professionals, and clubs might agree on the same basis.

When Crouch was at Portsmouth I believe that significant %of his remuneration was paid via his image rights. I am speaking from memory now but it equated to something like £50 for every shirt that had his name printed on it and there was very little evidence that the club used either his name or image on much else.

The IR as it was then challenged the administrators who by then had been appointed and whilst won the argument it had little impact in the Tax take . It was the club that was responsible for deducting the correct amount of tax/nic.

What happened then is that the tax authorities challenged in court the football creditor rule. The Enterprise Act 2002 stripped the right of IR and C&E to make a preferential claim meaning that the football authorities had in effect created a super preferential creditor . The tax authorities much to their surprise lost the challenge .

As part of the fall out was that HMRC as it was by then, agreed that there would a maximum % that could be paid as image rights but football clubs being what they are and players advisors even for academy players basically pushed it too far so the next attempt to control matters was requiring clubs to produce a costed case to justify the sums being paid but again players and agents being what they are pushed it too far in terms of payments off shore etc and as a consequence from next tax year all image rights payments will be treated as if they were made via payroll and will attract tax/ Nic.

HMRCs arguments around the payments to agents would be that they acted either on behalf of the player or on behalf of both parties.

It is the player’s responsibility to pay for those that act on their behalf. The argument almost certainly would be that the 3rd party individuals even not registered in the UK were indeed acting on behalf of the player.

It’s commonplace for clubs to agree to fund any player costs but payments in that regard are treated as being a benefit in kind to the player recorded ( well it used to be) on a P11D and as the player is on a UK payroll tax &Class 1 Nic is payable by the club.

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15 hours ago, terraloon said:

When Crouch was at Portsmouth I believe that significant %of his remuneration was paid via his image rights. I am speaking from memory now but it equated to something like £50 for every shirt that had his name printed on it and there was very little evidence that the club used either his name or image on much else.

The IR as it was then challenged the administrators who by then had been appointed and whilst won the argument it had little impact in the Tax take . It was the club that was responsible for deducting the correct amount of tax/nic.

What happened then is that the tax authorities challenged in court the football creditor rule. The Enterprise Act 2002 stripped the right of IR and C&E to make a preferential claim meaning that the football authorities had in effect created a super preferential creditor . The tax authorities much to their surprise lost the challenge .

As part of the fall out was that HMRC as it was by then, agreed that there would a maximum % that could be paid as image rights but football clubs being what they are and players advisors even for academy players basically pushed it too far so the next attempt to control matters was requiring clubs to produce a costed case to justify the sums being paid but again players and agents being what they are pushed it too far in terms of payments off shore etc and as a consequence from next tax year all image rights payments will be treated as if they were made via payroll and will attract tax/ Nic.

HMRCs arguments around the payments to agents would be that they acted either on behalf of the player or on behalf of both parties.

It is the player’s responsibility to pay for those that act on their behalf. The argument almost certainly would be that the 3rd party individuals even not registered in the UK were indeed acting on behalf of the player.

It’s commonplace for clubs to agree to fund any player costs but payments in that regard are treated as being a benefit in kind to the player recorded ( well it used to be) on a P11D and as the player is on a UK payroll tax &Class 1 Nic is payable by the club.

Ooof. So that stands to be what, a ~30% increase to clubs in player costs then? UEFA clubs must be rubbing their hands with glee.

If Spain is anything to go by, unfortunately it tends to minimally affect the top clubs while limiting the economic competitiveness of smaller ones. That probably won't be a bad thing for Euro clubs struggling to compete with mid-table PL clubs on revenue.

5 hours ago, SydneyChelsea said:

Ooof. So that stands to be what, a ~30% increase to clubs in player costs then? UEFA clubs must be rubbing their hands with glee.

If Spain is anything to go by, unfortunately it tends to minimally affect the top clubs while limiting the economic competitiveness of smaller ones. That probably won't be a bad thing for Euro clubs struggling to compete with mid-table PL clubs on revenue.

Not sure it will increase by 30% but it will come at a cost. Clubs will somehow have to come to some sort of arrangement when it comes to new contracts . Players won’t expect to have to pay !

Bearing in mind that any agreement to pay IR has to be supported by in effect a business case then as you look at clubs who generate less in terms of commercial/ sponsorship then the lower a club is ( apologies) down the food chain then the less they can justify.

It’s been interesting watching the saga surrounding Vinicius jnr. It appears that Real own all his image rights although not the norm that restricts his ability to earn from personal endorsements . I struggle to believe the numbers but it is claimed that the income generated from personal endorsements covers the total of his wage.