HMRC have published new Guidelines for Compliance aimed at football agents and clubs, setting out their view on dual-representation contracts (where the agent purports to work for both the club and the player, and the fee paid by the club to the agent is characterised as a split between the two).
In essence HMRC take the view that agents work primarily for the player and fees for services should be apportioned accordingly. ‘HMRC does not accept a 50/50 split in agents’ fees as the default position’, says the guidance. The guidelines provide an example of why this is significant, showing the contrasting tax, NIC and VAT implications depending on whether the fee is deemed to be made on behalf of the player or on behalf of the club.
Tax Policy Associates covered dual-representation contract arrangements in March 2023, setting out two clear examples of the typical structures used by clubs.
HMRC have published new Guidelines for Compliance aimed at football agents and clubs, setting out their view on dual-representation contracts (where the agent purports to work for both the club and the player, and the fee paid by the club to the agent is characterised as a split between the two).
In essence HMRC take the view that agents work primarily for the player and fees for services should be apportioned accordingly. ‘HMRC does not accept a 50/50 split in agents’ fees as the default position’, says the guidance. The guidelines provide an example of why this is significant, showing the contrasting tax, NIC and VAT implications depending on whether the fee is deemed to be made on behalf of the player or on behalf of the club.
Tax Policy Associates covered dual-representation contract arrangements in March 2023, setting out two clear examples of the typical structures used by clubs.
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