A tax expert has raised questions about the potential UK tax treatment of payments. They relate to former Manchester City manager Roberto Mancini following the publication of the independent commission’s findings.
Dan Neidle, founder of Tax Policy Associates, has published a preliminary analysis examining whether payments made under Mancini’s consultancy arrangement with Abu Dhabi club Al Jazira could have created a UK tax liability.
Tax Policy Associates examines Mancini payments
The arrangement existed alongside Mancini’s employment as Man City manager and was examined as part of the Premier League proceedings.
The independent commission found the arrangement to be a sham and concluded that £8.866m funded by Abu Dhabi United Group related to remuneration that should have been included in Mancini’s contract with City.
City dispute the commission’s findings and intend to appeal.
In its preliminary tax analysis, Tax Policy Associates argues that the payments identified by the commission could therefore have been subject to UK income tax and National Insurance. Its calculation estimates a potential original liability of £11.6m.
That figure is not an assessment or demand from HMRC.
Neidle makes clear that he doesn’t know whether HMRC investigated the arrangements or, if it did, whether any matter was subsequently resolved. Tax Policy Associates says its conclusions are based on the information currently available.
There has been no public finding from HMRC that City owe £11.6m in relation to the arrangements.
The analysis follows the independent commission’s findings against City, which remain subject to the club’s proposed appeal.
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