Why Transfer Pricing Is Relevant to Premiership Football
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Reproduced with permission from Tax Planning International Transfer Pricing, null, 06/19/2009. Copyright 2009 by The Bureau of National Affairs, Inc. (800-372-1033) http://www.bna.com Why transfer pricing is relevant to premiership football Graham Poole, Pim Fris and Tom Coriano NERA Economic Consulting, London and Paris How do you make a small fortune in football? By starting with a large one. he saga over the failed £100m plus transfer of I. Background Brazilian superstar Kaka´ from AC Milan to Manchester City in the January transfer In June 2003, Russian billionaire Roman Abramovich T bought Chelsea F.C. for £140m, the biggest-ever trans- window highlighted yet again the absurdities of Pre- miership football.1 In recent years, a staggering pro- action involving the sale of an English football club. cession of billionaires has bought clubs, most with the During the same year, American businessman Mal- aim of turning a sleeping giant into a champion. Of colm Glazer started to acquire increasing sharehold- course, only one club at a time can be champions, and ings in Manchester United. Two years later, he bought it comes as no surprise that several of the most the club in a takeover valuing it at approximately famous clubs in English football are reported as being £800m, delisting it from the Stock Exchange, and technically insolvent.2 This has given rise to concerns pushing through a compulsory buyout of all remain- that Premiership football has lost touch with reality ing shareholders. and that at some point, possibly as a result of a bene- More recently, the city of Manchester has witnessed factor getting bored or running into financial difficul- further acts of footballing theatre. In July 2007 the ties, one or more will come unstuck. Albeit in different former Prime Minister of Thailand, Thaksin Shina- circumstances, this is what happened to the once watra, completed the takeover of Manchester City for great Leeds United. £81.6m. In January 2008, after his Thai assets had This article examines how various concepts and been frozen because of corruption charges faced in analytical methods used in transfer pricing could pro- Thailand, Mr. Shinawatra sold the club to the Abu vide a sensible framework for restoring a semblance Dhabi United Group (ADUG), an investment group of sense and balance to Premiership finances.3 Spe- backed by Sheikh Mansour bin Zayed Al Nahyan, the cifically, the application of these approaches to what brother of the ruler of Abu Dhabi. The Sheikh has are essentially related party transactions could curb spent £210m buying a 90 percent stake in Manchester the distorting effects of utility-maximising behaviour City with the intent of turning it into a top four club by club owners.4 Over a period of time, this would within three seasons. bring the interaction between clubs and their owners These are only few examples of the increasing role closer to what might be expected were the relevant played by billionaires and foreign investors in the Pre- parties dealing entirely at arm’s length. It would also mier League. Table 1 illustrates the growing influence provide a financial safety net for the clubs themselves. of billionaires in the Premiership, together with a In this sense, the framework discussed in this article snapshot of key financial data for Premiership clubs. could provide an objective means of bolstering the The data illustrate the magnitude of Premiership going concern test recently proposed by the Premier club debts. The alarming levels of gearing, reportedly The authors thank League. 220 percent on average in 2007, have led some com- Emmanuel The idea for this article started off as something mentators to define the Premiership as the last finan- Llinares, also of semi-serious, but developed from there. It highlights cial bubble.5 NERA, for the point that transfer pricing is not all about compli- The above notwithstanding, figures for individual comments on the ance, or even tax planning; it can, and often does, lie clubs do not all tell the same story. This is illustrated draft of this article at the very root of organisational behaviour. by data for the clubs with the highest total debts in 06/09 Tax Planning International Transfer Pricing BNA ISSN 1472-0841 1 Table 1: A Snapshot of Premier League Clubs Financial Data – 2007 (£m) Football Club Current Ownership1 Turnover PBT2 Total Debt Arsenal3 A. Usmanov (25%), S. Kroenke (20.5%), Others (54.5%) 201 6 420 haAston Villa R. Lerner 37 -3 64 Blackburn Rovers The Jack Walker Trust 43 -3 17 Bolton E. Davies 51 -2 40 Chelsea R. Abramovich 190 -76 609 Everton B. Kenwright (37.2%), R. Earl (34.6%), J. Woods (28.2%) 51 -9 31 Fulham M. Al Fayed 39 -16 188 Hull City P. Duffen 9 -2 2 Liverpool T. Hicks (50%), G. Gillet (50%) 134 -22 350 Manchester City Abu Dhabi United Group 57 -11 110 Manchester United Glazer family 210 -63 667 Middlesbrough S. Gibson 48 -8 93 Newcastle United M. Ashley 87 -33 73 Portsmouth A. Gaydamak 52 -23 42 Stoke City P. Coates 8 -3 6 Sunderland Drumaville Consortium 26 -15 53 Tottenham Hotspur ENIC International Ltd (82%), J. Lewis, D. Levy 103 28 45 West Bromwich Albion Majority shareholder J. Peace 24 5 4 West Ham United4 B. Gudmunddson. Parent company currently in administration 57 -22 77 Wigan Athletic D. Whelan and S. Kornberg 27 -8 54 Sources: NERA Economic Consulting calculations based on miscellaneous sources of data. Notes: 1 Ownership data as of 1 May 2009. 2 Profit Before Tax. 3 A. Usmanov’s holdings held through the company Red & White Holdings Ltd. 4 At the time of writing this article, West Ham United was facing imminent takeover by a consortium of international banks. 2007. Manchester United’s indebtedness, for instance, capacity and over-fishing in open access fisheries). is mostly related to the refinancing of borrowings con- Clubs overspend and assume increasing levels of tracted by the Glazer family in their highly geared debts in an effort to compete, to the detriment of club takeover of Manchester United. The new owners have finances and the benefit of players and their agents. In loaded their own borrowings on the club, which is this regard, the Premiership tops the list of European now burdened with high annual interest payments. Leagues for the highest and fastest growing total wage The same is true of Liverpool, which had £44.8m of expenditure. Specifically, England’s top clubs have debts before its takeover by Messrs Hicks and Gillet spent more in recent years than the rest of the big five and now has debts of £350m. Arsenal’s debts in con- European Leagues combined. The effects on clubs’ fi- trast are mainly due to expenditure of £133.5m in- nances are alarming. According to Equifax, a credit curred to redevelop the old Highbury stadium into information provider, 10 clubs in the Premiership are flats, and to the £260m borrowed to build the new technically insolvent,6 as demonstrated in Table 2. Emirates stadium, a major source of increased turn- Often the clubs’ debts are financed through interest- over for the club ( plus 46 percent year-on-year in free loans from billionaire owners, as, for example, in 2007). On the other hand, Chelsea’s debts originate the case of Chelsea, a practice that has been criticised primarily from players’ transfer fees and salaries. as ‘‘economic doping’’. At an international level, They have recently been halved by Mr. Abramovich, UEFA, Europe’s football governing body, has argued turning £369.9m of his interest-free loans into shares that the dominance of Premier League clubs in in the club, thus bringing his total investment in Europe is built on unsustainable levels of debt which Chelsea since 2003 to £710m. Although its current distort the level playing field in Europe. UEFA has debts are comparatively low, Manchester City’s debts hinted that it would like rules to be reformed in the di- may soon achieve similar levels. Sheikh Mansour re- rection of financial fair play so that clubs must oper- portedly intends to spend more than £540m in re- ate within their resources. building the team, starting with the £32.5m already Against this background, the current economic spent for Robinho. crisis will further increase the strain on clubs’ fi- Such spending patterns result in an upwards spiral nances, as well as on the fortunes of their billionaire of transfer fees and wages in a fashion that will be fa- owners. Revenue streams are under pressure, with de- miliar, for example, to economists addressing the clines in corporate hospitality and season ticket re- common property resource problem in a prisoner’s di- newals expected. Advertising and merchandising lemma setting (e.g., ‘‘capital stuffing’’ leading to over- revenues are also falling, at least for smaller clubs, 06/09 Tax Planning International Transfer Pricing BNA ISSN 1472-0841 2 Leeds United entered administration, thus incurring a Table 2: Equifax Credit Scoring Football League-imposed point deduction, which rel- Solvent Insolvent egated the club to the third tier of English football for Team Score1 Team Score1 the 2007–08 season. Leeds United’s experience of ad- ministration is not isolated in English football. Since Arsenal 98 Everton 18 1992 there have been 48 other examples, the most Manchester United 93 Stoke City 17 recent being Southampton, previously a Premiership 7 West Bromwich Albion 71 Chelsea 10 Club. This scenario has prompted a debate on what could and should be done to restore financial disci- Tottenham Hotspur 65 Middlesborough 7 pline to the Premiership. Proposals range from the Blackburn Rovers 43 Bolton 5 adoption of salary caps to the introduction of player Manchester City 40 Newcastle United 5 quotas.