HMRC tackles football clubs over questionable R&D tax relief

HMRC tackles football clubs over questionable R&D tax relief

A top-flight Scottish football club is appealing a demand from HM Revenue and Customs (HMRC) to repay £1.27 million claimed under a research and development (R&D) tax credit scheme, partly for player salaries.

Dundee United claimed the tax relief based on a report from its consultant, ZLX, which asserted that players spent 24% of their time on R&D projects, including nutrition and data collection. The report also claimed 80% of the club chef’s time was spent on nutrition science research.

The R&D scheme is designed to support genuine advances in science and technology that benefit an entire field, not just a single business. However, experts have dismissed the club’s justification. Simon Brundish, a conditioning coach who has worked with Premier League teams, described the activities as “standard practice in professional team sport” and not “groundbreaking”. Tax expert Dan Neidle labelled the notion of claiming a quarter of players’ salaries as R&D expenditure a “scandal”, stating, “Football players are not scientific researchers”.

This case highlights broader concerns about the misuse of the R&D scheme, which has faced scrutiny for lax checks leading to significant fraud and error. HMRC has revealed that at least 33 professional football clubs are under investigation regarding £17 million in potentially wrongful claims, The Times reports.



Several English Premiership clubs have also made large claims, including Chelsea (over £3m), Nottingham Forest (£607,000), Fulham (£758,000), and Brentford (over £3m). It is not confirmed if these claims included player salaries.

The role of tax advisers has also been questioned. ZLX, which described itself as having the “know-how” to navigate the scheme, was previously criticised in a Scottish court for proposing an R&D claim for the installation of a fridge. Stephen McCallion, owner of ZLX, stated the briefing document for Dundee United’s claim was never submitted to HMRC and declined to comment on whether player salaries were included, citing client confidentiality.

The cost of the R&D scheme has grown from £1.1 billion in 2010 to £7.5bn in 2023, with estimated losses to fraud and error totalling £4.1bn since 2020. Dundee United’s accounts confirm it is appealing against HMRC’s repayment demand.

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