Matthew Pryke’s Post

⚽⚽⚽ Updated HMRC Guidelines for Football Agents, Clubs, and Players on Dual Representation Contracts⚽⚽⚽ HMRC have released updated guidelines explaining their view of the correct tax treatment of football agent/intermediary fees. Key points to consider 🏆: 1️⃣ Dual Representation: The guidelines clarify HMRC's stance on dual representation, emphasising the need for a commercial justification for the split of agent fees between player and club services. 2️⃣ Audit Trails: A strong emphasis is placed on maintaining detailed records and evidence to support the tax position taken in dual representation contracts. 3️⃣ FA Regulations: The guidelines address the new FA Football Agent Regulations effective from 1 January 2024, reminding stakeholders that compliance with FA rules does not negate the need to consider these guidelines. 4️⃣ Employment Reporting Obligations: The document outlines the reporting obligations for clubs when paying agents' fees on behalf of players, including the correct handling of PAYE and National Insurance contributions. 5️⃣ VAT: Commentary is also provided in respect of the recoverability of VAT on dual representation contracts, including evidence and record keeping to be maintained in support of any recovery. #sportstax #sportslaw #football #footballagents #fifa #theFA #transferwindow

I’ve just published an article on the HMRC Football Agent Regulations, effective January 1, 2024. These new guidelines highlight the tax implications of agents’ fees and emphasise the need for thorough documentation in dual representation cases. ⚽📑 Key Points: Default assumption: Agents’ services are primarily for players, incurring income tax. Substantial evidence required for a 50/50 split of services between player and club. Detailed documentation needed for dual representation arrangements to comply with HMRC. For a comprehensive understanding of these changes, check out the full article here: https://lnkd.in/dWBvkYak #Football #HMRC #TaxRegulations #SportsLaw #FootballAgents

Please see our article on HMRC's new guidance on dual representation contracts between football clubs, agents and football players and the tax impact on them. If you would like to discuss this please do not hesitate to contact me or your DWF contact. #dwf #uk #tax #hmrc #dwfsport #contracts #sport #football

❎ #HMRC - New Guidelines Released for Football Agents and Dual Representation Contracts ⚽️ In a bid to streamline compliance efforts within the football industry, a set of comprehensive Guidelines for Compliance (GfC) has been unveiled, targeting #FootballAgents and #Clubs alike. 🏟️ The key highlights of these guidelines include: 📌 Insights into HMRC’s stance on #DualRepresentationContracts. 📌 Detailed examination of #EmployerDuty and #VATCompliance risks pertaining to Football Agents’ fees and dual representation. While these guidelines offer clarity in specific areas, it's important to emphasize that they do not alter existing compliance perspectives on other taxes. Stakeholders are advised to consult HM Revenue & Customs’s official guidance in conjunction with these newly released guidelines.📕 By adhering to these recommendations, agents and clubs can significantly reduce the risk of errors and potential penalty charges. ✅ HM Revenue & Customs | FIFA | UEFA https://lnkd.in/deWxbqFi

What clubs, players & agents need to know about HMRC’s new guidance on football agents’ fees and dual representation: https://bit.ly/3VE5gLx HMRC published new guidance on 13 May 2024: 'Help with Football Agents’ Fees and Dual Representation Contracts' This article examines the key points of this guidance: ➡️ HMRC’s evolving view on dual representation ➡️ Why HMRC are placing the burden on the player ➡️ What HMRC want to see to evidence genuine dual representation ➡️ Is HMRC’s new approach fair? ➡️ The importance of contemporaneous evidence ➡️ What to do if the transfer happens at the last minute ➡️ Key points to remember Thank you to Patrick Way KC for contributing this article. Field Court Tax Chambers #sportslaw #tax

HMRC has published new guidance for football agents and clubs engaging in dual representation contracts. The key message is that it will be scrutinising dual representation arrangements as it perceives this area as being subject to manipulation by agents, clubs, and players. The guidance stresses the importance of thorough documentation to evidence the scope of services provided to each party by agents. Read our summary: https://bit.ly/4bjn6JJ If you have any questions about this new guidance or any other tax queries, please contact our expert Tax team. #dwf #uk #legal #tax #hmrc #contracts #sport #football

I wrote an article about The FA's recent introduction (sort of) of the new Football Agent Regulations (which implement FIFA's Football Agent Regulations (FFAR)) and the uncertain tax consequences arising therefrom. It'll be interesting to see how the challenges to FFAR around the world play out but, either way, expect HMRC to continue to enquire about football transactions involving dual representation and third-party intermediaries for the foreseeable future. #football #footballagent #footballbusiness #footballclub #hmrc #taxlaw #taxcompliance

Ian's written a great piece here about the introduction of the new Football Agent Regulations and the potential tax consequences. Agency relationships almost always have complexities from a VAT perspective. In particular where a supply of agency services could have multiple recipients and some of those recipients are VAT-sensitive. We're increasingly seeing tax authorities applying a regulatory-lens to transactions. New regulations will therefore always have tax consequences. Any questions on these proposals please feel free to reach out either directly to Ian or I would be happy to introduce you. #Tax #VAT #Football #PinsentMasons