A new approach by HMRC could potentially result in players being liable for significantly more tax.
The new guidance is also set to impact the payment of agents’ fees by football clubs when negotiating transfers and new contracts, with HMRC no longer accepting 50:50 split of services provided by an agent to both club and player.
Last year, more than 240 footballers were investigated by HMRC during the tax year, up from 87 in 2019.
Adam Craggs, partner and head of Tax Disputes, Regulatory and Financial Crime at RPC, said: “This new guidance formalises the approach that HMRC has started to adopt in enquiries into the tax returns of an increasing number of footballers in recent years.
“This formalisation may foreshadow an increased focus by HMRC on the payment by clubs of agents’ fees on behalf of players.”
He added: “The indications are that HMRC hopes to increase the tax yield for the Exchequer by focussing on this area and increasing the amount of tax paid by professional footballers.”