Two sanctions issued on 28 October against Atlético de Madrid by the Fourth Division of the Contested Administrative Division of the National Court exceeded 600,000 euros, and a third against Sevilla FC on 6 September amounted to 2.3 million euros. He maintained his stance against fraud allegations facing Spain’s top clubs since 2015, arguing that powerful football representatives earned substantial sums from players and transfers.
These National Court decisions against Sevilla and Atlético de Madrid align with the criteria established since 2019. They reflect the same pattern seen when Real Madrid, FC Barcelona, and Valencia CF paid managers, a move that also benefited players. In any case, allegations raised by Real Madrid and former Valencia CF player Víctor Ruiz suggest that the Supreme Court will ultimately decide the fate of the multi-million sanctions on the so‑called nobility of Spanish football, with at least two appeals on the facts on record.
In the latest sanctions accessed by EL PERIÓDICO DE ESPAÑA from Prensa Ibérica, Atlético Madrid is noted for paying 469,756 euros to the Treasury as VAT that was deducted from payments to player representatives in 2010 and 2013, a deduction that also reduces the combined cost of up to six signatures, transfers, or renewals, respectively.
multiple players
In this manner, the National Court affirms the position of the Central Economic Administrative Court and sets resource amounts at 247,290 euros and 222,466 euros, respectively. In the first case, the order concerns 2010 Non-Resident Income Tax on dealings with the representative organizations NCS Universal Rights BV and IMG Overseas. The second case establishes the 2013 Non-Resident Income Tax sanction on transactions executed by Atlético de Madrid with Essel Sports Management and SMTM entities. Among others, interventions on contracts involving footballers José Antonio Reyes, José Manuel Jurado, and Toby Alderweireld are cited.
The Treasury Inspectorate also rejected Sevilla FC’s version, arguing that the managers offered a service commissioned by the club: “The claimant does not demonstrate any internal procedure the club designed to determine its needs, nor present documentation proving how the so‑called contracted services were defined, nor entrusted to intermediaries.” The September resolution emphasizes that there was no established mechanism to control the execution of work or to standardize the tasks of various intermediaries. It also notes that the representative Promoesport Baster BCN was involved in actions tied to a person affiliated with the SL agency in the 2013 period.
Valencia CF
In the Valencia CF case, another National Court judgment from 23 March upholds two prior rulings by the Central Economic-Administrative Court from 24 June 2020 and 25 January 2021, requiring the team to pay 2,234,905 euros.
One of the players affected is Víctor Ruiz, who left Valencia for Napoli in 2011. On 25 July 2016, the Regional Inspection Unit of the Special Delegation of Valencia issued a provisional personal income tax assessment for 2011, 2012, and 2013 for 163,485 euros, as described in a separate report dated 15 June. This arrangement arose because the athlete did not disclose payments made by Valencia CF to his representative.
Evidence indicating the agent’s role on behalf of the player is seen in an invoice issued by Tacle Players 80 SL for 120,000 euros, described as a commission payment for negotiating the professional footballer’s employment contract with Valencia CF SAD for the 2011-2016 seasons, after Napoli’s transfer to Valencia. The player later moved to Villarreal in 2014 and currently plays for Real Betis.
jorge mendes
In the same vein, the Contested-Administrative Chamber confirmed the Treasury decisions of May and June 2021 in five additional rulings. Real Madrid is found to have deducted 3.2 million euros in VAT from funds paid to managers and players. Specifically, in the Mourinho era, the representative Gestifute International Limited, led by Jorge Mendes, faced a total of 400,000 euros in questions.
The treasury inspectorate explained that the arrangements were clear and that the manager was paid by Real Madrid, leading to a reduced taxable income if handled correctly. These payments, not included in the deductible expenses for personal work income, could not be treated as work income. Consequently, the inspectorate asserted that the payments overseen by Real Madrid to Gestifute were misrepresented in the personal income tax base for Mourinho for the years 2010-2011. The National Court, however, later annulled certain tax assessments for the then Roma coach for years 2010, 2011, and 2012, in line with anticipated sanctions.
The Contested-Administrative Division of the National Court, in the September 6 ruling against Sevilla FC, joined two other judgments from 12 June and 13 May 2019 that FC Barcelona preferred an ex-player’s manager for payments to Gerard Pique to reduce personal income tax liabilities.
“The way it works”
The so‑called working style of these clubs, now upheld by the National Court, was outlined by the Treasury Inspectorate. It revealed that teams paid commissions from player contracts to managers. This arrangement benefited clubs financially by covering VAT costs and reducing the overall outlay for transfers, signings, or renewals. The Fourth Division of the National Court’s 6 September ruling against Sevilla FC mirrors this pattern.
At the same time, the arrangement benefited players, who were often exempt from VAT payments or could lower their IRPF liabilities. The contentious-administrative judges of the National Court highlight these effects as part of the broader debate.
Ultimately, the Central Economic-Administrative Court supported the Treasury’s stance, finding that payments to players’ representatives improved the athletes’ position by associating the funds with the services rendered. It concluded that the payments should be treated as income to the players, given that the services implicated directly affected and benefited the athletes. This conclusion aligns with the court’s earlier decisions and the Treasury’s interpretation of the relevant tax rules.