Taxing solidarity: the VAT treatment of FIFA training rewards in Spain - a guide for football clubs

This article examines the legal and tax treatment of training reward payments within the FIFA transfer system. It first explains the nature and function of both training compensation and the solidarity mechanism under Articles 20 and 21 and Annexes 4 and 5 of the FIFA RSTP (January 2025 edition)^[1], and the role of the FIFA Clearing House in administering payments. It then analyses how Spanish tax authorities treat such payments for VAT purposes. 

Notably, it explains how Spain’s Dirección General de Tributos (General Director of Taxes - DGT^[2]) has interpreted such payments as consideration for the taxable supply of services, and addresses the related issues of place of supply, invoicing obligations and determination of the taxable base. It concludes by offering practical guidance for football clubs and their advisers on structuring and documenting training reward payments in a manner consistent with FIFA regulations and Spanish VAT law.

Readers already familiar with the regulatory nature and function of FIFA’s training rewards and Clearing House are welcome to move straight to section three: “VAT characterisation of training rewards in Spain”.

Article overview

• FIFA’s training rewards framework
  • Background
  • Regulatory basis and structure
  • Legal nature and function - redistribution
• The role of the FIFA Clearing House
  • Centralisation of payments
  • Intermediary character
• VAT characterisation of training rewards in Spain
  • The DGT's position: consideration, not compensation
  • Identification of the supplier, recipient and place of supply
  • Determination of the taxable amount (net or VAT-inclusive?)
  • Invoicing duties and who bears the tax risk
• Practical takeaway points for clubs