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HMRC internal manual

Employment Income Manual

HM Revenue & Customs
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Tax treatment of Association footballers: payments to non- contract and amateur players

If a non-contract or amateur player receives no more than the reasonable out of pocket expenses incurred in travelling to matches (home or away), or cleaning and maintaining his kit, no tax liability arises. The principles relating to voluntary workers will apply (see EIM71100).

However, where a payment or series of payments to a non-contract or amateur player appears to include a clear element of remuneration, for example appearance money, you should consider whether there is an oral or implied contract that makes the player an employee of the club. The Employment Status Manual (ESM) provides guidance on the factors to be considered.

You will also need to consider whether the terms of engagement of the player are similar to those applying to contract players. Other matters, such as the obligations imposed on keeping fit, training, availability for selection, times of reporting for matches, taking of instructions from managers and other officials, discipline and club rules and regulations generally may also be of relevance. (This content has been withheld because of exemptions in the Freedom of Information Act 2000)