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View metadata, citation and similar papers at core.ac.uk brought to you by CORE UEFA’s Financial Fair Play provided by Anglia Ruskin Research Online Regulations: the devil is in the detail

by Tom Serby1

Introduction ing in the top divisions of the European Bayern München FC, Manchester United countries had grown over the previous FC, Chelsea FC and Arsenal FC.7 “The devil is in the detail, and we’re try- five years by an average annual amount ing to get to grips with this devil…”2, the of 5.6% (more than ten times the average The reason for the presence of many words of Michel Platini, President of the rate of growth of the economies of these English football clubs in this list is that Union of European Football Associations countries), to a total of € 13.2 billion. The entrance into the English Premiership (“UEFA”), in August 2013, commenting total revenues (excluding transfer fees) of League (“EPL”) is considered the most lu- on UEFA’s Financial Fair Play Regula- the “big five” leagues doubled from € 4.2 crative move in world sport, with the latest tions (“the Regulations”). The intention billion to € 8.4 billion (reflecting partly the television rights for the period 2013-2016 of the Regulations is simple: an attempt to increased value of the broadcasting deals concluded by the Premiership on behalf of restore financial prudence in the operation secured for television rights). these elite 20 clubs at £ 3.018 billion, a rise of the biggest European football clubs. of 70% over the previous deal. Wealthy The details of how the Regulations can Meanwhile, Deloitte’s published fig- individuals, “sugar-daddy ownership” in achieve this are complex. This article will ures for the first decade of the twenty- Lang’s phrase8, tempted by the prestige explain the “devilish detail” through an first century5 show that, while there has the EPL offers, buy up clubs, and spend analysis of how UEFA, for the first time been steady growth in income terms of extraordinary amounts of money to buy in 2014, begins the process of enforce- the top flight clubs in Europe, aggregate success. It has been reported that Sheikh ment of the Regulations. The article will net losses of these clubs has tripled since Mansour bin Zayed Al Nahyan of Abu consider why the Regulations were intro- 2007 to reach € 1.7 billion, with 63% of Dhabi has invested over five years £ 1 bil- duced, the likely impact they will have on the clubs operating at a loss in 2011. The lion in Manchester City FC, just slightly top flight European football clubs and the major contributing factor to the losses has more than Roman Abramovich, the Rus- likelihood of a legal challenge to them. been the increased spending by clubs bid- sian oligarch, has invested in Chelsea FC ding against one another to attract a small since 2003. Wealthy owners of clubs in the global pool of the most talented players, league below the Premiership, the Foot- Background to FFP Regulations in an attempt to engineer success on the ball League Championship, go to simi- pitch. Muller, Lammett and Hovemann6 larly extraordinary lengths to buy a place Financial overspending by sports’ clubs is provide an excellent analysis of the “rat in the wealthiest league in world football; not limited to football clubs, but the most race” engaged in by the top clubs all aspir- a good example being Cardiff City FC. egregious examples of financial reckless- ing to partake in the most lucrative com- Cardiff obtained promotion into the EPL ness over the years have occurred within petitions by buying success in the shape at the end of the 2012-2013 season at a the ranks of top flight European football of exponentially growing transfer fees. huge cost. Accounts filed at Companies clubs. The collapse of one of Europe’s pre- Gambling on success in this way inevita- House for the year ending 31 May 2013 eminent football clubs Glasgow Rangers bly produces losers as well as winners in a reported an operating loss of £ 30.9 mil- FC in 2012 illustrates that no football club financial sense. lion up from £ 13 million in the previous is too big to suffer financial disaster. Com- season. Wages and salaries accounted for menting on this case a select committee of Although sporting fiscal irresponsibility £ 27 million compared to £ 18.5 million in the House of Commons, the lower House is not unique to European football, it has the previous year. The BBC reported Car- of the UK Parliament, commented that it become in recent years a growing problem diff’s Chairman Mehmet Dalman admitt- was “a powerful example of the excesses in the sport. In April 2014, it was revealed ting that Malaysian businessman Vincent of professional clubs in competing with in the Global Sports Salaries Survey 2014, Tan had invested £ 150 million in the club one another, and the consequences for compiled by the Sportingintelligence since 2010.9 their community when mismanagement website and ESPN The Magazine, that the leads to financial collapse”.3 English Premiership club Manchester City The Regulations’ objective is to bring fi- FC now tops the global wages league for nancial order back into European football. For decades, top flight European football athletes, with the average first team player has experienced the curious phenomenon at the club now paid £ 5.3 million a year of rising income based on the sport’s grow- (£ 102,653 a week). Second on the list are Theoretical justifications for the FFP ing popularity, coupled with increasing the New York Yankees, and also appearing Regulations financial losses. According to the UEFA on the list of the top twelve highest paying Benchmarking Report for the financial wage earners are the major European foot- Muller, Lammett and Hovemann10 sum- year 20114, the income of the clubs play- ball clubs Real Madrid FC, Barcelona FC, marise that ““la crème de la crème” of

6 June 2014 © Nolot European football includes a string of League clubs have to pay football credi- on large scale cash injections to buy new clubs with significantly loss-making busi- tors before other creditors or face expul- (and better) players “restoring efficient ness models that in “normal” industries, sion from the League (which would nor- managerial incentives” will result in a where profitability is the criterion for sur- mally lead to the club’s dissolution). In its better brand of management. “The time for vival, would fall into bankruptcy”. They latest report, the committee recommended repeated managerial moral hazard and refer to the practice of wealthy business- bringing forward legislation to outlaw rent-seeking games in European football men bankrolling topflight football clubs as the rule which it branded “immoral”, but is over if FFP comes into action. Foot- “financial doping”. They argue that there has recommended delaying any new law ball managers will have to concentrate on is a theoretical justification for a sporting until the Financial Fair Play rules, which productive efforts to develop the football regulatory body (in this case UEFA) to have been introduced into English football business as a whole and in a sustainable step in and control the extent of financial (based on, but a variation of, the Regula- way instead of focusing on “payroll-gam- aid being used to buy sporting success. tions), have been allowed to work and are bling” in a sort of “football casino” .”21 They argue that allowing sporting success tested. to be controlled by off the pitch compe- tition to attract the richest “sugar daddy” Football’s regulators were keen, therefore, The Regulations: in brief is a violation of sporting ethical standards to bring in rules to attempt to curb the in- and the spirit of the competition. creasing overspending by clubs; but critics The Regulations were introduced in 2011 have been quick to assert that the Regula- as an extension to UEFA’s existing club Dietl, Franck and Lang11 cite some of the tions infringe European competition law. licensing system. The principal objectives characteristics specific to the football in- Further to the well-known ground break- of the Regulations are defined in art. 2.2 dustry that tend to increase expenditure ing decision of the Court of Justice of the as follows: by wealthy owners above and beyond European Union (as it is now known) in what would be the case assuming rational Bosman16, rules and regulations of sports “a to improve the economic and finan- behaviour and a profit-maximising clubs governing bodies must comply, where the cial capability of the clubs, increasing (what Franck calls the phenomenon of rules have an economic impact which ob- their transparency and credibility; overinvestment through revenue dissipa- viously the Regulations do, with European b to place the necessary importance on tion): a strong connection between invest- Union law, for example competition law, the protection of creditors and to en- ment in players and on field success; an contained in art. 101 and 102 of the Treaty sure that clubs settle their liabilities “additional exogenous prize” (e.g., UEFA on the Functioning of the European Un- with players, social/tax authorities Champions League qualification); and a ion. and other clubs punctually; system of promotion and relegation with c to introduce more discipline and ra- a large financial impact attached. In an attempt to analyse the probable ef- tionality in club football finances; fect of the Regulations on competition, d to encourage clubs to operate on the Franck says that the term “arms race” is the Regulations have been the subject of basis of their own revenues; not really strong enough to describe the several academic economic studies. An e to encourage responsible spending for extreme amounts invested and hence huge economic modelling based on the impact the long-term benefit of football; losses incurred in top flight European foot- of the Regulations by Madden17 concludes f to protect the long-term viability and ball; he refers instead to a “zombie race”12, that “the imposition of FFP makes all par- sustainability of European club foot- and refers to the literature on the “too big ties (fans, owners and players) worse off, ball.” to fail” phenomenon13. Van Rompuy14 has primarily because of the adverse impact calculated that, as of September 2012, it has on all team and league qualities”. Michel Platini has stated that the introduc- Spanish football clubs owed the State a Madden argues that the Regulations will tion of the “financial fair play concept”: combined € 1.3 billion in taxes and social deny clubs the benefits accruing from sub- security. There is an expectation that the stantial injections of external money. “…should not be seen as a call for aus- State will not pull the plug as too much terity and a return to the budgets of old. cultural, communal and emotional invest- Peeters and Szymanski18 conclude that Football moves impressive amounts of ment is invested by the Spanish people in the net result of the Regulations over time money and that is a good thing. Nor is football. will be a fall in the wage to turnover ratio it a question of seeking a utopian dis- of clubs. They go so far as to characterise tribution of wealth. There have always It is not just commentators who have the Regulations as a form of horizontal re- been clubs that are richer than others called for new regulations to restore great- striction on competition. Vopel and Sass19 and there doubtless always will be. All er solvency in top flight football clubs. The argue that under the Regulations it will we want is for clubs – richer and poorer clubs themselves cooperated with UEFA be more difficult to build up a new team, alike – to spend no more than they earn in drafting the Regulations, and legisla- thereby consolidating the position of the and to balance their books, this being tors too have expressed disquiet with the current top teams, in effect thereby creat- the only sure way for them to survive.” financial culture in football. For example, ing a “barrier to entry” to the top table of the UK Parliament (more specifically the clubs by aspiring newcomers who will be There is a requirement under the Regu- House of Commons Department for Cul- restricted from taking the route of clubs lations, in the words of the explanatory ture, Media and Sport select committee) such as Manchester City FC and Chelsea document on UEFA’s website22, for clubs has undertaken two recent enquiries into FC and buying success. to prove that they: football governance in the UK, including a review of the so-called Football Creditors Franck20 posits the contrary view, con- “do not have overdue payables towards rule15. Under this rule, EPL and Football cluding that when clubs can no longer rely other clubs, their players and social/

© Nolot June 2014 7 tax authorities throughout the season. gate and, if necessary, adapt the calcu- UEFA has already shown its resolve, In other words, they have to prove they lations of the break-even result for the through imposition of tough sanctions have paid their bills.” sponsorship revenues to the level which (fines and exclusion from UEFA competi- is appropriate (“fair value”) according tions) against Turkish clubs Besiktas and The other rule introduced by the Regula- to market prices.”23 Bursaspor, and Hungarian club Gyori for tions is the “break-even” rule, which is breach of the other aspect of the Regula- the focus of this article. Sanctions for this The overall intention of the break-even tions, failing to pay creditors as debts fall rule have effect from the 2013-2014 sea- rule is to limit the amount of financial as- due (decisions upheld by CAS). However, son, and it is a requirement for clubs to sistance a wealthy individual can extend to these clubs are not the top flight clubs that balance their books over the two preced- a club, in other words to restrict “financial fall under the scrutiny of the break-even ing years (increasing to three years from doping” and the role of the “sugar daddy”. element of the Regulations. 2014-2015) between income from football Competition on the field, rather than com- related activities and expenditure (for ex- petition off it to secure a wealthy backer As stated above, the Regulations have ample players’ wages and transfer fees). should determine clubs’ success under the led to individual member country asso- Art. 58.1 of the Regulations states: Regulations. ciations, for example the Football As- sociation, football’s governing body in “Relevant income is defined as revenue The Regulations bind all clubs eligible for England, agreeing their own version of Fi- from gate receipts, broadcasting rights, competition in UEFA’s European compe- nancial Fair Play Regulations for the EPL sponsorship and advertising, commer- titions, the Champions League (in which and separately for the Football League. cial activities and other operating in- the previous season’s higher placed clubs come, plus either profit on disposal of in the highest domestic divisions in each player registrations or income from dis- European country compete) and the Eu- Spotlight on the Manchester City FC posal of player registrations, excess pro- ropa League, for the second tier of best and Etihad Airways relationship and ceeds on disposal of tangible fixed assets performing clubs. the case of St Germain FC and finance income. It does not include any non-monetary items or certain in- A club taking part in a European compe- Following UEFA’s announcement by its come from non-football operations.” tition must submit the required licensing General Secretary, Gianni Infantino, earli- documentation to their national football er in 2014, that 76 clubs, almost a third of The break-even rule is subject to a number association. Investigation into compliance the total 237 involved in European compe- of exceptions: with the Regulations can be requested titions, were being investigated by UEFA by UEFA’s Club Financial Control Panel on suspicion of contravention of the Reg- – exemptions for expenditure on stadia/ (“CFCP”), who have the power to con- ulations, Alasdair Bell, UEFA’s legal af- training grounds and development of duct audits of the clubs in order to verify fairs director, commented that UEFA was youth sections/academies; whether the correct licensing decision expecting legal challenges to be made by – contracts with players signed before was reached by the domestic association, clubs but articulated UEFA’s stomach for 2010 are not included (for the first two and if necessary impose sanctions. These the fight: “We are not afraid of [UEFA de- seasons under consideration); sanctions are various and at the discre- cisions] being contested,” Bell said. “We – an “acceptable deviation” is possible, tion of UEFA, the most serious sanction fully anticipate there will be challenges – currently € 5 million over the previous being a ban on a club from taking part in it would be strange if there weren’t. July two years, or up to € 45 million if the the Champions League, which if applied and August could be a busy time.”26 Mr shortfall is covered by equity invest- would naturally have very significant fi- Bell added that any clubs exceeding the ment (i.e. subsidy by a wealthy nancial consequences for a club (under the break-even requirements by more than owner), reducing from 2015-2016 to € 5 latest broadcasting deal for UK TV rights 20% faced the strictest sanctions of with- million or € 30 million (equity) over for Champions League and Europa League drawal of up to five players from their 25 the previous three seasons. matches BT Sport has agreed an exclusive strong UEFA competition squads with re- deal with UEFA worth £ 897 million over peat offenders facing outright disqualifi- One potentially complex area of the Regu- three years from 2015-2016 season; and cation the following season.27 lations, which is discussed further below currently each of the 32 clubs participat- in the context of specific clubs such as ing in the Champions League group stages Two clubs in particular, Manchester City Manchester City FC and Paris St Germain receives £ 7 million plus £ 396,000 each FC and Paris St Germain FC, were high- FC, is how the break-even rule is affected match played).24 Other, lesser, sanctions lighted in media reports in early 2014 by sponsorship of a club by a party related that UEFA may impose for a breach of as significantly non-compliant with the to the club’s owner(s). In essence only the Regulations include fines and points Regulations. In the case of both clubs the to the extent that the sponsorship repre- deductions, and prevention of registration spotlight has been on sponsorship deals by sents good value based on a hypothetical of new players for UEFA competitions or parties related to the owners, which under “arm’s-length” transaction can it count to- a reduction in the squad size permitted for the Regulations, as discussed above, must wards income. UEFA’s description of the a European competition. UEFA’s general be assessed in terms of their “fair value” rule is as follows: secretary, Gianni Infantino, has stated: in order for the income to count towards balancing the clubs’ books. In 2011, a “If a club’s owner injects money into the “We would bar clubs in breach of the multi million pound sponsorship and nam- club through a sponsorship deal with a rules from playing in the Champions ing deal was agreed between Manchester company to which he is related, then League or the Europa League. Other- City FC and Etihad Airways, owned by UEFA’s competent bodies will investi- wise, we lose all credibility.” 25 the government, whose ruler

8 June 2014 © Nolot Sheikh Khalifa is the brother of Man- 1 Is the sponsorship a related party trans- rather than science. Given the enormous chester City’s owner, Sheik Mansour. At a action (“RPT”)? amounts of money involved, it is highly conservative estimate, the deal is reputed foreseeable that clubs will have spent con- to be worth £ 350 million over 10 years. 2 If so, is the deal concluded on a “fair siderable amounts on legal fees already In the case of Paris St Germain FC, a £ value”? To answer this the Panel would negotiating with UEFA’s CFCP the effect 167 million a year contract with the Qatar need to break down the deal into its con- of these words. Tourism Authority attracted the scrutiny stituent parts, as the sponsorship cov- of UEFA’s Club Financial Control Panel. ered three separate elements and did not Obviously, only if the sponsorship is a Re- specify their respective proportions: lated Party Transaction (“RPT”) need the Manchester City FC’s 2010-2011 accounts issue of “fair value” be addressed. In rela- announced a loss of £ 99 million and the a (re)naming rights for the Etihad sta- tion to this question Annex X (E.7) of the players’ wages bill stood at the unfeasibly dium; Regulations state: high level of 114% of its turnover; while b shirt sponsorship; and around the same time Paris St Germain c development of the . “A related party transaction may, or spent £ 127 million on recruiting some of may not, have taken place at fair value the sport’s global superstars, Ibrahimovic, A benchmarking exercise would be [...] An arrangement or a transaction Silva and Lavezzi. Manchester City FC’s required to apportion the three strands is deemed to be “not transacted on an 2012-2013 accounts showed a loss of £ of the deal, and comparators would then arm’s length basis” if it has been en- 52 million and represented a slight im- need to be sought, in relation to e.g. tered into on terms more favourable to provement, but this was largely down to shirt sponsorship deals. This exercise either party to the arrangement than a deal selling the players’ image rights for is, of course, fraught with difficulty. would have been obtained if there had £ 47 million, which many have criticised So many imponderables are present. been no related party relationship.” as creative accounting designed to work The benchmarking exercise would around the Regulations.28 Manchester City need to posit the chances of the club In reality, UEFA’s CFCP might well invert FC’s 2012-2013 accounts were published competing in the highest competitions the questions and first assess whether a in January 2014, four months before the (e.g. the Champions League) in future sponsorship deal represents fair value be- CFCP’s anticipated announcement, due in years, since this would affect the fore addressing the first question, i.e is it May 2014, regarding breaches of the Reg- club’s goodwill on which the value a RPT? Of course the two are linked be- ulations. Khaldoon Al-Mubarak, chairman of the sponsorship deal is predicated; cause, if “fair value” is not present, then of Manchester City, was quoted as saying, and in the case of a long fixed term surely this is evidence of a RPT? deal, such as Manchester City FC’s, “I am very comfortable, very confident an estimate would need to be taken of In May 2014, it was widely reported that with our financial operation and our un- the commercial value of the deal in nine clubs had agreed to accept sanctions derstanding of the UEFA rules.”29 ten years time; clubs would no doubt for breach of the break-even requirement point to the exponentially growing TV of the Regulations. Both Manchester City As has been stated, the Regulations pro- deals etc., to justify long term deals FC and Paris St Germain FC were report- vide at art. 58 to 63 that, under the break- which may appear in the short term as edly facing fines (€ 60 million over three even requirement, the only income that excessive. The imponderables make the years) and a reduction in squad size (25 counts is pure footballing or “operating sport’s core commercial currency, and to 21) for European competitions, coupled income”, in effect, gate receipts, revenue hence the “fair value” of sponsorship with a cap on their wage bill. Failure to from broadcasting deals and sponsorship. deals very difficult to value. agree the sanction by either club would It is commonly accepted that sponsorship mean the matter being passed to the Club is footballing or operating income as it re- RPTs are dealt with at Annex X, section Financial Control Body’s Adjudicatory lates to payment for the goodwill arising E of the Regulations at pages 83ff.31 The Chamber, chaired by the Portuguese judge from the footballing activities of the club. relevant part is at Annex X (E.2), which José Narciso da Cunha Rodrigues, lead- As Nixon30 points out, such sponsorship states: ing potentially to an even harsher punish- income is quite different to income from a ment, such as exclusion from the Cham- side-line business, such as hotel or proper- “2 A person or a close member of pions League. The Court of Arbitration ty purchases, which could not be included that person’s family is related to a for Sport would hear any appeal from that in a club’s operating income. And yet, the reporting entity if that person: body over the summer so as to minimise Etihad sponsorship, which included nam- disruption to the 2014-2015 season. ing rights for Manchester City FC’s sta- a has control or joint control over dium, was perceived by many as a strategy the reporting entity; The Regulations provide for a challenge for circumventing the break-even rule. b has significant influence over the within ten days of a formal sanction being When compared, however, to sponsorship reporting entity; or imposed by any other club on the grounds and naming rights secured by other large c is a member of the key manage- that the sanction is unfair (i.e. not harsh clubs, Manchester City FC argued that the ment personnel of the report- enough). However, any argument by a sponsorship was “fair value”. ing entity or of a parent of the rival club that a Champions League ban reporting entity.” should be the consequence of a breach To determine this question, the issues to is counter-productive as it would dimin- be decided by UEFA’s Club Financial It can be seen that terms such as “signifi- ish the brand if the biggest clubs are in- Control Panel are as follows: cant influence” and to a lesser extent “key eligible, and it ignores how complex the management personnel” are terms of art Regulations are. Arsène Wenger’s32 call

© Nolot June 2014 9 for clubs to be banned where they breach The European Commission supports the achieving the outcome of greater fiscal the Regulations: “You would think that Regulations; however, this is no guaran- prudence. Other measures that might have you accept the rules and you’re in the tee that the Regulations’ legality would been followed to introduce better financial competition, or you don’t accept the rules be upheld in court. Jean-Louis Dupont control would include salary caps, as is the and you’re not in the competition” might (the lawyer who sucessfully represented case in cricket in both the Indian Premier be ascribed to gamesmanship.33 Bosman) is instructed by player’s agent League and English professional cricket, Daniel Striani in a claim before the Euro- and, indeed, in the EPL’s own Financial pean Court, commenced in 2013, seeking Fair Play Regulations ratified in April Can the Regulations have an impact a declaration under art. 101 of the Treaty 2013. Critics of the Regulations have ar- and will they withstand any legal on the Functioning of the European Union gued that the focus on “over generous” challenge? that the Regulations infringe EU compe- backers is wrong and that the Regulations tition law as they create “a barrier to en- completely ignore the more serious issue newspaper’s review of all try”, and consolidate the position at the of owners of clubs, such as Portsmouth EPL club accounts for the 2012-2013 top of the table of the existing top clubs, FC, Birmingham City FC and Manchester season, published on 1 May 201434, con- as well as depressing the wages of foot- United FC, unscrupulously using clubs for cludes that clubs paid their players and ballers (and of course their agents). It was their own financial ends.38 other staff a record £ 1.8 billion in 2012- also reported in February 2014 that Shaun 2013, up 11% on the previous year; and Harvey, the Chief Executive of the Foot- that, despite a combined income of £ 2.7 ball League (representing the three high- Conclusions billion, the clubs as a whole made an ag- est divisions in English football behind the gregate loss of £ 291 million. With five EPL), had written to all Football League UEFA have worked closely with the clubs, clubs losing £ 50 million or more (Aston clubs promising to maintain the Football both in introducing the rules, and in im- Villa, Chelsea, Liverpool, Manchester League’s own FFP rules: plementing them for the first time in May City and Queens Park Rangers) twelve 2014. In 2010, Michel Platini, President of the twenty clubs made a loss in 2012- “The League has received a letter from of UEFA, worked with the European Club 2013. The report concluded that the EPL Brabners solicitors on behalf of sev- Association in drafting the Regulations clubs’ net debt increased to £ 2.4 billion eral unnamed Championship (and one and accepted changes to them at their in- in 2012-2013, from £ 2.2 billion in 2011- League One) clubs which raises a num- stigation. 2012. This analysis obviously calls into ber of issues including the potential of a question the impact that the Regulations legal challenge.”36 The Regulations contain a “settlement” have made to date, at least in the EPL. option allowing individual clubs ten days Not surprisingly, UEFA’s take on its own Paragraph 4.7 of the Commission’s 2007 to negotiate the finding of the CFCP. The “Club Benchmarking Report: 2013/14 White Paper on Sport,37 acknowledges ro- choice of a fine (€ 60 million over three season”35 was more upbeat in regard to bust licensing systems as a “tool for pro- years) and reduction in squad size (25 to the signs that the Regulations were begin- moting good governance in sport”; and 21) for European competitions coupled ning to make a positive impact on club UEFA, of course, argue that the Regula- with a cap on the wage bill as a penalty for solvency. It remains to be seen whether tions, in seeking to curb excessive debt, Manchester City FC and Paris St Germain actual sanctions for breach of the Regu- represent good governance. The question FC is an indication that the Regulations lations will engender any change in the for the Court would be whether the Regu- are to be implemented gradually. overspending culture. lations represent a proportionate way of

10 June 2014 © Nolot 24 1 Solicitor Advocate, Senior Fellow of Higher 12 Egon P. Franck, Financial Fair Play in European BBC, Champions League: BT Sport wins £ 897 Education Academy, and Senior Lecturer in Law Club Football – What is it all about?, Work- million football rights deal (2013), available at at Anglia Ruskin University, Cambridge. Tom ing Paper no 328, p. 7, (University of Zurich www.bbc.com/sport/0/football/24879138. 25 can be contacted at [email protected]. Department of Business administration, 2014). D. Conn, Michel Platini will expel debt-laden 2 H. Winter, “Michel Platini warns European Availalble at www.business.uzh.ch/forschung/ clubs from the Champions League (2010), avail- Clubs he will take them to court to force through wps.html. able at www.theguardian.com/football/2010/ Financial Fair Play” (2013), available at www. 13 Egon P. Franck, Financial Fair Play in European aug/26/michel-platini-champions-league. 26 telegraph.co.uk/sport/football/10277543/Michel- Club Football – What is it all about?, Work- www.theguardian.com/football/2014/feb/28/ Platini-warns-European-clubs-he-will-take-them- ing Paper no 328, p. 8, 9, (University of Zurich -challenges-financial-fair-play. 27 to-court-to-force-through-Financial-Fair-Play. Department of Business administration, 2014). I. McDonald and K. Andrews, “Playing Ball html. Availalble at www.business.uzh.ch/forschung/ with Financial Fair Play?”, in: Sport in the Law 3 Culture, Media and Sport Committee – Fourth wps.html. (2012). 28 Report: Football Governance follow up (2013), 14 Ben Van Rompuy, “Plan to relieve the Span- O. Gibson, The Guardian, 6 May 2014. 29 www.publications.parliament.uk/pa/cm201213/ ish football club tax debts” (2012), available BBC, Manchester City: club cmselect/cmcumeds/509/50902.htm. at http://footballperspectives.org/plan-relieve- upbeat despite £51.6m loss (2014), available at 4 UEFA, The European Club Licensing Bench- spanish-football-club-tax-debts. www.bbc.com/sport/0/football/25951455. 30 marking Report Financial Year 2011 (UEFA, 15 For a fuller discussion see: T. Serby, British A. Nixon, “Sponsorship: Financial Fair Play and 2013), available at: www.uefa.com/Multi- football club insolvency: regulatory reform Competition Rules”, in: Sport in the Law (2011), mediaFiles/Download/Tech/uefaorg/Gener- inevitable? (ISLJ, 2014). available at www.lawinsport.com/articles/ al/01/91/61/84/1916184_DOWNLOAD.pdf. 16 Union Royale Belge des Sociétés de Football competition-law/item/sponsorship-financial-fair- 5 Deloitte Sports Business Group, Pressure to Association ASBL v. Jean-Marc Bosman (1995), play-and-competition-rules. 31 change – Annual review of football finance (De- http://eur-lex.europa.eu/LexUriServ/LexUriServ. UEFA Club Licensing and Financial Fair Play loitte, Manchester, UK 2011). do?uri=CELEX:12002E039:EN:NOT. Regulations (2012), available at www.uefa.org/ 6 Muller et al, “The Financial Fair Play Regula- 17 P. 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