Sports Invest UK Ltd v HMRC

In Sports Invest UK Ltd v HMRC [2023] UKFTT 376 (TC) (18 April 2023) the First-tier Tribunal (FTT) held that 4m euros paid by a club to a football agent for a player transfer solely related to services supplied to the club and was not partially third-party consideration for services supplied to the player. Consequently the supply was not subject to UK VAT. 

The appellant Sports Invest (SI) was a UK company providing football agency services. Services were provided for the transfer of a player from Sporting (a Portuguese club) to Inter (an Italian club) in 2016. The agent received payment of 4m euros from Inter for the transfer. No payment was made to the agent by the player. 

There were two key agreements and a waiver that were pertinent to the VAT position. The first agreement was a ‘player representation agreement’ between SI and the player. Under...