Man City: HMRC urged to review tax implications of ruling announced by Premier League

As part of their appeal, Manchester City will claim that key sponsorship deals are funded by the government of Abu Dhabi, not the club’s owners.

Owners of Abu Dhabi United Group (ADUG), the private investment company owned by UAE Vice President and Deputy Prime Minister Sheikh Mansour, are said to have inflated the value of commercial deals by £830.69 million as part of a “secret financing scheme”.

It was claimed that this allowed the club to appear compliant with Premier League and UEFA financial regulations.

However, as first reported by the Daily Mail and Times, sources have told BBC Sport that City are expected to tell the Appeals Board they have evidence to show that the money directed to sponsors came from the Abu Dhabi government and not ADUG.

Premier League rules allow public bodies to sponsor clubs.

The independent commission detailed that City “deny any secret funding scheme alleged by the Premier League”. [it] Abu Dhabi had misunderstood how the sponsorship deal was financed… That was the reality [the club contested] That the Abu Dhabi sponsors are always responsible for all registered sponsorship fees and that in fact all are paid to the club by the Abu Dhabi sponsors from their own funds/resources.

“No part of the recorded sponsorship fee has been paid by ADUG or from the use of ADUG funds. Abu Dhabi sponsors have from time to time applied to the Government of Abu Dhabi for financial assistance in relation to the obligation to pay recorded sponsorship fees – such applications have been granted…”

An independent panel dismissed the submission as “untrue”, saying: “We concluded that this was a well-made ‘explanation’ after the fact in an attempt by the club to cover up and hide the realities of a disguised funding scheme.”

City’s argument is likely to spark renewed debate about the extent to which City’s ownership is separate from the state of Abu Dhabi and the implications of club ownership for state relations.

Mansour is a member of Abu Dhabi’s ruling family and the brother of Sheikh Mohammed bin Zayed Al Nahyan, the president of the UAE.

Since its takeover in 2008, City have insisted the club is a wholly-owned, not state-owned, enterprise. However, some critics have questioned this distinction, with human rights activists claiming that City’s ownership is being used to “launder sports” for the UAE.

On Saturday, City chairman Khaldoon Al Mubarak cited “irrefutable evidence” which he claimed supported the club’s claims of innocence. The city argued that the commission’s decision was “consisting of clear material errors of law, principle and fact and is dangerous.”

It turned out that Al Mubarak, who was appointed as the mayor of the city after taking power in 2008, was listed as an Emirati diplomat in the list of all foreign representatives of the British government.

Representatives of foreign countries and their diplomatic staff enjoy privileges and immunities under the Diplomatic Privileges Act (1964), which gives diplomats immunity from prosecution under criminal, civil, and administrative law.

City’s main sponsor, Etihad Airways, said it was considering legal action against the Premier League, claiming the release of the commission’s findings had “prejudicial consequences … despite the fact that the airline was not named in the redacted published results”.

The UAE’s state-owned national airline said it “strongly rejects any finding, finding or implication that the airline has ever engaged in improper commercial arrangements”.

Etihad is owned by L’Imad sovereign fund, which is headed by the crown prince of Abu Dhabi, son of the UAE president.

The Premier League declined to comment when contacted by BBC Sport.

Additional reporting by James Landale, BBC News’ diplomatic correspondent.

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