In answer to a question posed by Labour MP Peter Dowd, Mel Stride, financial secretary to the Treasury, said HMRC currently has enquiries into 38 clubs, 90 players and 13 agents.

This is more than double the number of clubs and individuals under investigation compared to the responses given by HMRC CEO Jon Thompson to the public accounts committee (PAC) last year. At that point, the figures were 12 football clubs, 43 footballers and eight agents under inquiry around the issue of image rights.

Thompson 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 ‘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.’

In his response to Dowd, Stride said: ‘HMRC has a project looking at all compliance risks in football to ensure that football clubs, players, managers and agents pay the correct amount of tax. Since 2014-15 HMRC has brought in over £260m from tackling non-compliance in the football industry.’

The Treasury initiated a specific football compliance project in April 2017, and has announced that technical experts will visit all English Premier League, Championship and Scottish Premier League clubs over a three-year period.

The specialist squad 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.

At Spring Budget 2017 the Chancellor announced HMRC would publish guidance on image rights payments to clarify for all employers what tax treatment should be used for such payments. This was published on 16 August.

Guidance on tax on payments for the use of image rights is here.

Report by Pat Sweet