The club has provisioned the amount but assures that this sentence does not entail any payment obligation
BARCELONA, 9 Feb. (EUROPA PRESS) –
FC Barcelona will appeal to the Supreme Court against the ruling of the National Court that imposes on the Blaugrana club the payment of almost 23 million euros for personal income tax for the years between 2012 and 2015 derived from the remuneration paid to the players' sports agents.
“FC Barcelona has been notified of the ruling of the Personal Income Tax (IRPF) section of the National Court in relation to the appeal presented by the club regarding the tax inspection that affected the remuneration paid to the agents. of the players between 2012 and 2015. FC Barcelona will present an appeal to the Supreme Court,” the club announced.
In a statement, the Barcelona entity assured that it is “surprising” that this section of the Contentious-Administrative Court of the National Court “has not taken into account the most recent jurisprudence of the Supreme Court in this regard”, and from which they have been able to “benefit” other football clubs in “recent sentences for the same problem.”
“The divergent criteria of the National Court is also surprising when a few months ago another section upheld an appeal by our club on an issue identical to the current one that derived from the same inspection in relation to the Non-Resident Income Tax,” said the club.
According to FC Barcelona, this ruling by the National Court does not entail “for the moment any payment obligation” for the club, which in any case has this contingency “duly provisioned in the annual accounts.”
In the ruling, to which Europa Press had access, the Fourth Contentious-Administrative Section of the AN rejects the appeal presented by the Blaugrana club against the TEAC resolution of June 2020, which in turn derived from the agreements of 2018 of the technical office of the Central Delegation of Large Taxpayers (DCGC) for which the liquidation and sanctioning resolutions were carried out for the concept of 'withholding/payment of personal income tax income on account' for the periods between January 2012 and June 2015.
The amount derived from the total tax settlement was 8,764,118 euros while, as a penalty, the payment of 3,031,893 euros (2012), 4,348,402 euros (2013), 5,172,955 euros (2014) was imposed. ) and 1,414,158 euros (2015).
As the resolution of the National Court explains, the underlying issue is the nature of the services provided by the players' agents.
The Administration, on the one hand, maintains that the remuneration paid by the club to the agents is in the nature of work income and is subject to withholding at the time of payment, so it is obliged to make and deposit the corresponding withholding. And this is because they understand that they provide their services to the footballers and not to the club, in accordance with the provisions of the Player Agent Regulations.
On the other hand, FC Barcelona understands that the amounts paid to the agents hired by the club correspond to the remuneration agreed for their services provided to the sports entity and, in this sense, it is not possible to attribute as remuneration to the players the amounts corresponding to provision of services to the club.