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Playing by the rules
Key points
- There are some unique areas of compliance that place a particular burden on football clubs including a renewed attention to the tax treatment of payments to intermediaries.
- HMRC will no longer accept a default 50/50 split being adopted between the fee allocated for the services provided to the club and those provided to the player for the purposes of calculating the taxes to be paid.
- Clubs should keep detailed records to prove how and why a particular split has been calculated based on services actually performed.
- HMRC guidance for football clubs is available – Employment Income Manual (EIM01150 to EIM01152).
Football clubs and players have long been a target of HMRC (and its predecessors’) attention going back to the House of Lords’ consideration of the income tax consequences of non-playing periods in Albion Rovers in 1952. However the scrutiny and attention has heightened significantly in recent...
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