EIM01151 | Football clubs: payments to intermediaries: indicators of risk

EIM01150 sets out details of HMRC’s position and requirements in cases where football clubs use the services of an intermediary (also known as agents) in negotiations with players, with particular reference to cases of dual representation. This page covers various indicators of risk that may cause HMRC to give further and more detailed review of arrangements into which clubs, agents and players enter.

Indicators that HMRC consider present additional risk include, but are not limited to:

1. Payments treated as a benefit to the player that are lower than the amounts those players are due to make to agents under existing player/ agent agreement.

2. Agents acting for both selling and buying club in the same transaction.

3. Payments to individuals who are connected with (or family members of) the players.

4. Payments to corporate (or other) entities that are controlled by individuals who are connected with family members of players

5. Payments to those acting as sub-agents.

6. Payments that are said to be 100% for club services where it is not clear that another party is acting for the player.

7. Payments to agents where they are said to act for corporate entities (typically based in tax havens) that appear to have little or no substance.

For examples of the records HMRC would expect to be kept to provide evidence of the arrangements entered into, and the commercial justification for payments that have been made, see EIM01152.