The specialist team will review all compliance risks including payments to players, to make sure the rules on image rights are applied consistently in football, the department said.

Details of the squad are revealed in the latest Treasury minutes published on 28 March, responding to a public accounts committee (PAC) report on the HMRC’s performance in collecting tax from high net worth individuals.

The Treasury minutes say the government is aware that some employers make image rights payments under separate contractual arrangements to those that generate employment income. Spring Budget 2017 announced that HMRC will publish guidelines for employers who make payments for image rights to their employees, to help employers understand how these payments should be taxed, which it says should improve compliance by clarifying what an image right is and the tests to determine whether payments can be treated as image rights payments or must be subject to PAYE as earnings.

Paul Noble, a tax investigations expert at law firm Pinsent Masons, said: ‘Football is a sport rich with money generated by sponsorship and television rights and involves many areas where tax may be at risk for HMRC and with this in mind it attracts a great deal of scrutiny and interest.’

An anonymised decision in a tax case published in 2000 confirmed that a sports person could have two income streams, one from playing the sport and a second from the use of 'image rights'. The payment for image rights would effectively be a rental payment for an intangible asset.

Noble explained that sports persons and celebrity entertainers typically assign their image rights to a company.  A football club may make payments to a player’s company to license the image rights from the company to enable the club to enter into an agreement with a sponsor to enable the sponsor to use the player’s picture or name.

If the player's company is a UK tax resident company, it will pay corporation tax on its profits from licensing the rights at 19%, under current rates, whereas the profits could be subject to income tax at 45% if received directly by the individual. A further tax saving arises from the fact that the football club will not be liable to employer's national insurance contributions (NICs) in respect of payments to the company in respect of image rights. Many footballers will not be UK domiciled for tax purposes and will hold their image rights through a non-UK company. This may mean that the payments escape UK tax altogether.

HMRC already collects information from football clubs to assess whether the balance between pay and image rights is reasonable. Jon Thompson, HMRC chief executive, told the PAC last year that the majority, but not all, of the clubs in the Premier League, supply HMRC with this information under a voluntary agreement.

He said at the time that 43 footballers, 8 agents and 12 football clubs were under inquiry around the issue of image rights.

‘There have been cases where we have queried player payments – when you get some reserve player no one’s ever heard of getting enormous amounts for image rights,’ Thompson said.

The latest Treasury minutes show HMRC has accepted other PAC recommendations. These include the suggestion HMRC should publish more information about its work generally alongside its next annual report and at regular intervals thereafter. PAC want this to include descriptions of key areas of its work, such as its approaches to tackling noncompliance and prosecutions; annual data on its operations, such as the number of criminal investigations in progress; and, progress updates on areas of public interest, such as its actions to investigate the data leaked in the Panama Papers.

HMRC also agreed with the recommendation of changing the name of the HNWI ‘customer relationship managers’, which PAC said suggested ‘an overly close and inappropriate service to the wealthy’. However it did not support the committee’s suggestion that it should conduct a formal evaluation of the high net worth unit and routinely monitor, analyse and report on the tax receipts from this group of taxpayers.

Treasury minutes 28 March are here.