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football and boots | accountingweb | Footballer transfer - where is the VAT hit?

HMRC ruled offside in football agent VAT appeal


A football agent received €4m for their part in an international transfer deal. But the VAT liability turned on what was being supplied and to whom.

12th May 2023
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Sports Invest UK Ltd operated as a VAT-registered football agent in the UK. It had three main activities:

  1. acting as an exclusive agent for various players, as recognised by the Football Association (FA)
  2. advising football clubs regarding players who would benefit the team if they were recruited
  3. assisting with negotiations between players and clubs in respect of transfers and the renewal of contracts. This could involve representing one, two or all three parties, depending on circumstances.

The FA provided a standard template agent agreement to Sports Invest. One of the clauses of the template specified that Sports Invest would receive a fixed percentage of client wages. However, Sports Invest’s business model was that they did not charge players fees and instead made all their money from the clubs themselves.

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Replies (8)

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By Justin Bryant
12th May 2023 15:51

Looks like the correct result and since there was no allegation of mislabeling (or sham), I'm surprised the Spectros line of cases re what is the correct consideration for something were not cited.

See also:

Thanks (0)
Replying to Justin Bryant:
By Hugo Fair
12th May 2023 16:59

I know you've been making a similar point for quite some time, Justin, but it really is beginning to look as though the 'deficient capability' bug that ran amok amongst HMRC's frontline staff is now bedding down in whatever passes for the 'shall we take this one to court' department!

Thanks (4)
Replying to Hugo Fair:
By Justin Bryant
13th May 2023 13:16

Yes, but I've also made the more pertinent point that you cannot really blame them when judges are biased (or just as bad, hopelessly incompetent) in their favour so often (this judge, who I know quite well, clearly is not one of those bad biased/incompetent ones)!

Incidentally, this case proved me largely if not totally right here:

Thanks (1)
By lionofludesch
14th May 2023 10:39

Ah - who is supplying what to whom?

It was ever thus.

Thanks (0)
By JCresswellTax
15th May 2023 10:00

Headline a bit boring, missed an opportunity to use VAR somehow.

Thanks (1)
Ivor Windybottom
By Ivor Windybottom
15th May 2023 10:10

HMRC are presumably chasing the bigger picture, as outlined here:

The first step is to establish who is supplying what to whom.

Thanks (1)
Replying to Ivor Windybottom:
By ds
15th May 2023 11:46

HMRC need to sharpen their Occam's Razor as well as their wits.
What is being supplied, by who and to whom.

Thanks (0)
By johnjenkins
16th May 2023 16:35

I have a similar case at the moment in the construction industry where assessments have been issued. The really stupid thing about this one is that it is all new work therefore zero rated. HMRC are aware but don't seem to care.

Thanks (0)