HMRC is trying to stamp out the payment of fees directly to the agent when they are acting for the club, which results in zero tax liability, as opposed to the scenario where the agent acts for the player.

The move comes as HMRC said it ‘recognises that dual representation contracts can be complex. The purpose of these guidelines is to set out our recommended approach to help customers pay the correct amount of tax’.

The risk heightens in cases where payments are made to agents, who then immediately disperse the payment to one or more other agents, increasing the risk of compliance checks.