A unique market with fluctuating prices and no reliable benchmarks

From a tax perspective, the lack of a transparent market and the difficulty in identifying truly comparable transactions effectively prevent the valuation of the right to sporting performances from being automatically equated with that of assets for which there are quotations or easily observable prices.

Any objections should therefore be supported by evidence going beyond a mere discrepancy between the value attributed by the parties and that subsequently deemed appropriate by the administration.

Furthermore, transactions that are formally independent but closely linked may be assessed as a single entity where their combination produces economic or tax effects that are difficult to explain on the basis of independent business reasons.

Even in this respect, however, the unique nature of the sector calls for caution: the purchase or sale of a footballer is frequently based on sporting, technical and strategic considerations that cannot be immediately translated into financial parameters.

These difficulties in assessment confirm the importance of reconstructing the methods used to determine each value. Documentation therefore becomes crucial because the assessment normally takes place some time later, when the player’s subsequent career development may inevitably influence the judgement on thetransaction in question. A player purchased for a modest sum may rapidly increase in value; conversely, a very substantial investment may prove to be a sporting failure. Neither of these outcomes, considered in isolation, demonstrates that the initial valuation was unreasonable.