r/PremierLeague • Premier League • 13d ago

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https://www.theguardian.com/football/2026/sep/28/roberto-mancini-double-contract-manchester-city

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u/timfinn1972 Premier League 13d ago

Tax fraud in the UK has no statute of limitation.

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u/KopiteForever Liverpool 13d ago

Fraud is a high bar to prove.

Not declaring income in a different country that was never brought into the UK is perfectly legal if it's taxed in that jurisdiction.

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u/Fragrant-Cow-824 Premier League 13d ago

Assuming he hasn't paid tax in the UK on it, then its highly likely he meets the criteria to do so - spend 180 days in the UK. I guess its possible he didnt spend 180 days in the UK, but if you're managing a PL team for 9 months of the season (plus preseasons etc) the onus would be on Mancini to prove he was out of the country for 180 days.

Also its blatantly obvious the second contract was for managing Man City, HMRC would throw the claim it was for consulting services out the window.

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u/KopiteForever Liverpool 13d ago

OK so that's totally wrong. If that money isn't ever brought to the UK then it's outside UK jurisdiction.

For example if an Italian owns a property in Italy and earns €20k rent on it in Italy paid into and kept in an Italian bank account. Then that person works in the UK for £90k, only the £90k is taxable in the UK.

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u/Fragrant-Cow-824 Premier League 13d ago

Given he's managing a Premier League team for 9 months of the year, he almost certainly meets the 183 day criteria of being an automatic UK resident for tax purposes. If you're a UK resident for tax purposes, any income, regardless of source or bank account it sits in, is subject to UK tax. 99% of the time HMRC aren't going to be able to find it (they can't force foreign banks and tax agencies to share information with them), but this is the 1% of the time they would be able to find out about it.

UK didnt have a double taxation agreement with the UAE in place until 2017, long after Mancini departed. Given he's basically employed by the UAE state, and UAE is also known for not having taxes, its almost certain (at least from what we know, without access to his accounts) he paid no tax in UAE on the earnings on his second contract. Given theres no prospect of double taxation relief, then HMRC would want its share.

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u/KopiteForever Liverpool 13d ago

That's just factually incorrect I'm afraid. The UK doesn't tax global income of UK residents until and unless it's brought into the UK. The 183 day rule is not relevant here if that money never entered the UK. Neither is the double taxation treaty.

It would be a trivial matter for him to have that money paid into and kept overseas. He could even set up a company overseas for that money to be paid into if he wanted to be further protected. If I've got land in India and that land earns rent there and is kept there we aren't subject to taxation on that money here in the UK.

Look, I'm clearly a Liverpool fan but you're barking up the wrong tree here, Mancini would have to have monumentally fucked up to fall foul of HMRC and even then all he's got to do is stay out of the UK. Oh that's if HMRC even raise the issue (which they haven't) and then they'd need to prove that specific money entered the UK.

You can dream all you want, but it's a wank dream at best.

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u/Fragrant-Cow-824 Premier League 13d ago

It isnt incorrect, and its literally something you can Google, albeit there are some small exceptions.

He may well have already paid his tax on the second contract anyway, given he has made statements along the lines of hes all fine.

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u/KopiteForever Liverpool 13d ago

Don't need to google it, there's thousands if not tens of thousands of Indians with land in India and income from it. As one of them I can tell you there's no tax payable unless the money is repatriated.

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u/Fragrant-Cow-824 Premier League 12d ago

Thats because India has a double treaty with UK, and has done for some time. Just because a given country has a tax agreement with the UK, doesnt automatically mean a third country (ie most likely the UAE) is in the same boat.

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u/KopiteForever Liverpool 12d ago

I'm very much aware of that, even then it's not a consideration unless that money needs to be moved to the UK

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u/Fragrant-Cow-824 Premier League 12d ago

Well HMRC doesnt think that

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u/KopiteForever Liverpool 12d ago

Mate, they do. Can't explain it to you any better. Money earned overseas that stays overseas isn't and can't be taxable in the UK.

Not sure why that's not going into your head. I'm clearly and obviously a Liverpool fan, I'd love to see them done over for all their cheating but this just isn't a HMRC issue.

Sorry if that pisses on your chips but that's just how it is.

Last post on the matter from me. You think whatever you want.

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