A separate contractual arrangement that Roberto Mancini held privately during his tenure as Manchester City manager has drawn the club into a potential dispute with tax authorities. Mancini, who manages the Italy national side, has stated that the consultancy arrangement linking him to a UAE club under Sheikh Mansour's ownership at Manchester City involved no misconduct on his part.
The arrangement, under which Mancini would receive £1.75 million annually, free of tax, in exchange for four days of coaching work per year at the Al Jazira Sports and Social Club, was characterised by an independent disciplinary commission as lacking genuine substance. The figure exceeded the £1.45m annual post-tax salary City were formally recorded as paying him in his role as head coach.
A three-member adjudicating panel determined that the payments made to Al Jazira had been channelled through Abu Dhabi United Group — the ownership body behind City — and constituted additional compensation directed at Mancini. According to Tax Policy Associates, a thinktank, the £8.87m in total payments fell within the scope of income tax and National Insurance obligations, with responsibility for ensuring those liabilities were met resting on City.
According to calculations by Dan Neidle, a financial journalist, the total liability facing City under the Mancini arrangement — once accrued interest and penalty charges are factored in alongside the unpaid tax — may reach approximately £24m. Specialists in tax law have indicated that financial penalties and potential criminal proceedings are among the consequences City and its leadership could be exposed to.
Penalties beyond the unpaid amount can follow even when the underlying error was unintentional. Anyone found to have intentionally evaded the law faces a prison term of as long as seven years.
Beyond the Mancini deal, the commission drew attention to two further arrangements involving unnamed parties, noting that those agreements may carry tax consequences as well. Separate scrutiny from HMRC is understood to extend to image rights arrangements between the club and its players — deals routed through a vehicle called Fordham yet drawing on funding traced back to ADUG — with investigators reportedly questioning whether those arrangements reflected genuine commercial activity.
According to the commission's findings, player payments attributed to image rights exceeded what those rights were genuinely worth, with the excess amounts functioning as a mechanism to boost overall compensation while avoiding the corresponding tax obligations. Tax authorities raised a claim against Portsmouth under a comparable arrangement when the club entered administration for the first time in 2010, with authorities concluding that image rights fees paid to footballers — Sol Campbell among them — exceeded what those arrangements were genuinely worth, applying the legal descriptor "sham" to characterise how the deals had been structured.
A comparable ruling came from both HMRC and the courts in relation to Rangers, the Glasgow-based club found to have channelled £47m to players and other staff through Employee Benefit Trusts structured to avoid tax liability. Questions of identity have long trailed Rangers — the club reconstituted after a 2012 liquidation order, itself triggered by outstanding tax debts, occupies a contested position in football, with many observers treating it as a new entity rather than the continuation of the old one.
According to the Premier League's formal charges, around £900 million passed through Manchester City's accounts via allegedly fraudulent transactions carried out over a nine-year period. Verdicts of guilt covered 114 of the original 115 allegations — a total that has since grown to 130 — distributed across six distinct rule-breach categories: inaccurate financial reporting on sponsorship income, related-party transactions, and operating expenditure across the nine seasons from 2009–10 to 2017–18 (50 counts); incomplete disclosure of managerial pay arrangements spanning 2009–10 to 2012–13 (8 counts); incomplete disclosure of player pay arrangements spanning 2010–11 to 2015–16 (12 counts); non-compliance with UEFA's licensing and financial fair-play framework across the five seasons from 2013–14 to 2017–18 (5 counts); contravention of Premier League profitability and sustainability requirements covering 2015–16 to 2017–18 (25 counts); and a failure to engage with the Premier League's own inquiry throughout the period from 2018–19 to 2022–23 (30 counts).
Facing a guilty verdict, the club — known by its Etihad Stadium home — has lodged an intention to appeal while maintaining that the charges against it have no foundation.
