Image rights pose a significant risk to football according to HMRC chief executive, Jon Thompson.

Thompson’s warning comes after it emerged Manchester United manager, Jose Mourinho and Real Madrid star, Cristiano Ronaldo could be investigated for their use of offshore companies to reduce tax bills, claims their agent, Jorge Mendes strongly denies.

It’s also understood that up to 43 players, 8 agents and 12 clubs were also under investigation by officials from HMRC with a dedicated team looking at image rights in football, other sports, and across the entertainment industry.

The HMRC’s head of enforcement, Jennie Grainger told the Commons Public Accounts Committee (PAC): “Just on football itself, in the last two years, that team, and wider across HMRC, has brought in £158m in yield.”

In order to set up an image rights company for a player, it must be clear that the individual has an image that has a value to sponsors. 

Some footballers and entertainers have income from image rights paid into offshore accounts without tax deducted. 

HMRC is investigating whether separate image rights earnings from earnings as players are genuine.

“Has it been properly transferred?” said Grainger. “Has it been transferred for a fair value? Should there be income coming back to the UK depending on their residency status? All of those issues can be part of this.”