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In a recent decision Sports Invest UK Limited (TC8797) the First-tier Tribunal (FTT) decided that the VAT treatment of a football agent’s fees should follow the contractual pattern.
Sports Invest UK Limited (the agent) a company incorporated and resident in the UK worked on the transfer of a football player (Joao Mario) from Sporting Clube de Portugal (Sporting) in Portugal to Inter Milan (Inter) in Italy. Under these arrangements the agent received a payment of €4m from Inter. The tax dispute related to the VAT treatment of these fees.
HMRC raised VAT assessments in relation to €3m of those fees. HMRC argued that although this fee was paid by Inter it was in fact a third-party payment of amounts due from the player to the agent. Since the player was not a business customer from a VAT perspective the place of supply of...
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