Allegation 2 – Mancini and Toure
By: Ted Fred Franky, Refuting misinformation, August 14, 2024 1 month ago
This section references the downloadable files found on this article at Der Spiegel – HERE
Preamble
In the murky world of leaked documents and high-stakes legal battles, it’s hard to discern what’s authentic and what isn’t. UEFA, in its case before the Court of Arbitration for Sport (CAS), presented six damning emails as evidence. However, it was revealed that one of these emails was actually a spliced version of two separate messages, deliberately altering the meaning. This raises serious questions about the integrity of the evidence, especially when coupled with the fact that many names and email addresses in the documents have been redacted.
The implications of these redactions could be far-reaching. For instance, if one of these concealed names were that of Richard Scudamore, the former chief executive of the Premier League, it would shatter the narrative that the Premier League was unaware of Manchester City’s dealings.
The documents in question seem to be a mix of emails and faxes, some of which have been copied multiple times, resulting in noticeable degradation in print quality. This degradation not only casts doubt on their authenticity but also makes it easier to alter the content. Without some form of electronic audit trail, there’s no way to confirm their genuineness.
When reviewing these emails, it’s crucial to understand that the motivations behind the actions and the missing background context are unknown. Rui Pinto, the hacker behind the Football Leaks, and Der Spiegel, the publication that reported on the leaks, have made assumptions of wrongdoing. Yet, neither seems to have the business acumen to understand the nuances of these transactions, relying instead on their vivid imaginations.
Roberto Mancini – Addtional Contract In Abu Dhabi
Based on info in RM.pdf downloadable from – HERE
One particularly contentious document relates to Roberto Mancini, Manchester City’s former manager. The emails suggest that payments made through Al Jazira FC were designed to cover Mancini’s tax liabilities. The intent appears to be ensuring Mancini didn’t end up paying tax both in the UK and Italy, a situation that could see him losing as much as 97% of his earnings.
The UK and Italy have a tax agreement intended to prevent double taxation, but the criteria for residency in each country differ. This creates a complex scenario where it’s conceivable that Mancini could meet the residency tests in both countries, leading to a dispute over which country should tax him. Such disputes are not uncoomon and can take years sometimes decades to resolve, so taking action beforehand to avoid this is a pretty good idea.
The documents suggest that one party, aware of these complications, designed a scheme to help Mancini avoid paying UK taxes on income he could declare in Italy. It is not clear who came up with this idea, whtehr it was standard practice, a tird party, Mancini’s agent, Manchester City or even the Premier League. This wasn’t an attempt to dodge taxes entirely, but rather to avoid being taxed in both countries.
The plan involved Mancini taking a consultancy job with Al Jazira FC, which required him to spend enough time outside the UK to fail the UK residency test. Having 4 trips to work on this contract in Abu Dhabi plus at least three UEFA away matches would ensure the 46 day threshold could always be avoided. Manchester City would then pay £1.8 million to Al Jazira FC, which would be forwarded to Mancini in Italy, allowing him to pay his taxes there on his £2 million net salary.
In the email on page 25, Silvia calcuates Mancini’s net salary to be £2,242,637 (A- Basic salary plus a bonus), the equivalent tax at 45.1% in Italy to be £1,842,311.99 [ B = 45.1% of (A / (100-45.1) ]
This arrangement is further corroborated by correspondence where Mancini’s agent, Sylvia (on page 48), requests additional documentation to present to the Italian tax authorities fom AJFC after Mancini’s dismissal from City. This suggests the scheme was designed to ensure compliance with Italian tax laws, and is totally above board in Italy, however convoluted it may seem to us.
It’s not implausible that similar arrangements have been made in the past within the Premier League. If the Premier League, specifically someone like Richard Scudamore, was informed of this arrangement, it would undermine the notion that the league was in the dark.
Other famous footballers and managers who are known to have used contracts to manipulate residency status include: Harry Kane, Robbie Keane, Gareth Bale, Rio Ferdinand, Harry Redknapp, Steven Gerrard, Wayne Rooney and David Beckham.
Rui Pinto’s actions, including splicing emails, indicate a willingness to manipulate the narrative. The redacted names and emails might conceal information that contradicts his accusations. While this entire scheme might seem convoluted, and international tax law is notoriously complex, it’s possible that such practices are not as uncommon as they might appear.
This is not about try to deceive the Premier League or anyone else it is simply delaing with a bad situation that might occur, and looking after an employee.
Andre Arshavin, Ian Holoway and Standard FA Contracts
Andre Arshavin signed for Arsenal, and both he and his agent misunderstood his pay. In the UK, salaries are always quoted gross before tax is deducted. In Europe, the standard is to quote salaries as net of tax. As a result Andre Arshavin ended up earning less at Arsenal than he was at his former club, and only realsied when he got his first pay slip.
Ian Holloway was boasting on TalkSport one day about when he was Bristol City manager, that they could not sack him. He explained that all footballers and all managers have to have standard contracts issued by the FA. These contracts cannot be altered in any way, they have clauses for pay, allowances, expenses and bonuses. The Standard Player Contract is usually printed on green paper and the Standard Manager Contract is printed on pink paper. One key difference is that players cannot be sacked, but managers can have their agreements terminated early. Holloway claimed that Bristol City had issued a green player contract when they appointed him as player-manager for both roles. Therefore they could not get rid of him. How true this is I do not know, but it highlghts an issue if it is.
If it is true, then Manchester City may have been in a difficult place in entering into this scheme with Mancini. City would have been forced to put his net salary on the Standard Contract where the gross salary usually goes. Since they cannot alter it in any way, they cant add notes about the other contract and so on. I am sure that City took advice over this and probably even shared the situation with the Premier League if only to ask for guidance as to what other clubs might have done in the past.
A lot has changed at the Premier League since then, Richard Scudamore ran it very well, but he is no longer there and this knolwedge and consent may not have been documented formally, and left when he left.
Regardless, it is obvious from the information supplied by Rui Pinto and Der Spiegel that this is a tax avoidance scheme to avoid paying tax twice, and not an additonal contract as they suggest. Furthermore, the whole scheme is finished before the start of the 2013-2014 season, and has no relevene to PSR.
Yaya Toure
Based on info in ADUG.pdf downloadable from – HERE
The first page clauses 2, 3 and 4 of the contract tells you all you need to know about this deal.
“ADUG wishes to secure the services of the Company (DS Management Ltd) and intends to work with the Subsiduary (Man City) and the othercompanies in its Group (ie CFG) to generate income in relation to the image rights.”
“ADUG will pay the Company for advice in relation to the Services and the exploitation of the Player’s (Toure) image rights and other football players (in the Group)”
This is nothing to do with paying Yaya Toure extra money.
As illuded to above, player contracts are standard contracts issued by the FA, they do not have iage rights associated with them. Image Rights (for appearing in advertisements on TV and in magazines and online), are contracted separately, usually with the money going into offshore tax free havens. This happens across all clubs with all players.
This contract is about Yaya Toure’s Image Rights agent, wanting to get him and other City players into adverts and make extra money.
The sums involved are 4 million Euros paid in two equal sums on 1st July 2010 & 1st June 2011. Again before PSR started.
A subsequent agreement has the sum of 4 million Euros paid in four equal sums on 1st July 2013, 1st July 2014, 1st December 2014, & 1st June 2015. So that’s 4 million Euros counting towards the 2013-2016 PSR calculations and 2 million Euros towards the 2014-2017 PSR calculations.
Related Articles:
- Summary – Overview of the Allegations
- Allegation 1 Analysis – Inflated Sponsorship
- Allegation 2 Analysis – Mancini and Toure
- Allegation 3 Analysis – The Own Goal
- Allegation 4 Analysis – It simply doesn’t add up
