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HMRC's Guidance on Agency Fee Taxation in Football

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HM Revenue & Customs (HMRC) have been clamping down on how tax is paid by football players over the last few years. On 31 March 2021, HMRC released new guidance. This guidance, along with the rise of investigations, indicates the changing attitude of HMRC to how tax on football agency fees will be handled going forward.  What was the position?  It is common in practice for an agent to represent both the player and the club in a transfer or contract negotiations. This is known as dual representation and is permitted by the Football Association under the current regulations.  When representing both player and club, agents would split the services provided for the player and services provided for the club 50:50 for the purposes of tax. This position was accepted by HMRC until now. The club would pay 100% of the agency fee, of which 50% of this (plus VAT) would be paid on behalf of the player for the services provided to the player as a benefit-in-kind. A player or his employer must de