In B Niasse v HMRC [2024] UKFTT 179 (TC) (28 February 2024) the FTT rejected the taxpayer’s claim to deduct fees paid to an agent for negotiating a transfer between football clubs.
The taxpayer Mr N was a professional footballer for Lokomotiv Moscow who transferred to Everton FC in 2016. To negotiate the transfer Mr N engaged an agent under a standard representation contract. He the agent and Everton then entered into a tripartite contract under which the agent would represent both the taxpayer and the club under which the agent would represent both in negotiations and would supply further services to the club while Mr N was employed by it. The tripartite contract provided for the fees payable by Mr N to the agent in respect of the transfer to be paid by Everton.
It was not in dispute that the payment by Everton of the...
