HMRC's view of football agents’ dual representation contracts clarified

New guidelines for compliance aimed at football agents and clubs sets out HMRC’s view on dual-representation contracts. These arrangements are where the agent works 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.

HMRC recognises that ‘dual representation contracts can be complex’ and says the purpose of the new guidelines is to set out its recommended approach to ensure ‘customers the correct amount of tax’.

The guidelines states that in such cases it will be necessary to allocate the agent’s fee between player and club services: ‘The split of payment value of the agent fee between player services and the club services must represent the commercial reality of the services provided. HMRC does not accept a 50/50 split in agents’ fees as the default position.’

An example is included showing the...