London, 7 October 2026 — EBM Newsdesk Analysis — By Katie Winearls
HM Revenue & Customs opened an investigation into Manchester City’s tax affairs in 2018, according to the Financial Times. The tax authority began examining whether the club had underpaid tax after its internal emails were leaked to Der Spiegel that year. Eight years later, an independent Premier League commission has found City guilty on 114 of 115 charges, including what it called £900m of “sham” deals. What has never been made public is what HMRC concluded, or whether it ever reached a conclusion.
That gap matters more now than it did a fortnight ago. A sporting panel has ruled on how City’s money moved. Who should have paid tax on that money is a separate question, and only HMRC can answer it.
The Mancini Question
Most attention is on one arrangement. Roberto Mancini, City’s manager between 2009 and 2013, had an employment contract with the club worth £1.45m a year after tax. Alongside it ran a “consultancy” deal that paid his Mauritian company £1.75m a year for four days’ work a year at Al Jazira, a football club in Abu Dhabi.
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SubscribeThe commission found that consultancy deal was a sham, and that City’s owner, Abu Dhabi United Group, funded the payments. If that money was really Mancini’s wages, it should have been taxed as wages under PAYE, with National Insurance on top.
Dan Neidle of Tax Policy Associates estimates the unpaid income tax and National Insurance at about £12m. With interest and penalties, he puts the total at £23m to £24m. That is his estimate. HMRC has not confirmed any figure. Mancini has previously said that everything during his time at City was above board.
City’s Position
City denies wrongdoing. The club says the commission’s decision contains “material errors of law, principle and fact” and is appealing. It has called the leaked documents “out-of-context materials purportedly hacked”. When asked directly whether the right PAYE and National Insurance were paid, it declined to comment.
There is no public record of a tax settlement in City’s accounts. HMRC does not comment on individual taxpayers. That leaves two possibilities. Either the inquiry is still open after eight years, or it ended quietly. Each raises its own questions.
Parliament Wants Answers
Dame Meg Hillier, chair of the Treasury Committee, has written to HMRC chief executive JP Marks. She wants to know whether HMRC has the commission’s full, unredacted report and what it is doing about football clubs’ tax practices. HMRC has until 15 October to reply.
The club’s chairman, Khaldoon Al Mubarak, holds diplomatic immunity in the UK, which makes any inquiry politically sensitive. City is also the best-known piece of a much larger body of Gulf investment across Europe, from airports to property. Britain wants that money, and HMRC has to stay independent of that.
Why Business Should Care
This is not only a football story. The arrangement the commission described, where an owner’s money is passed through a related company so that it looks like payment for a separate job, is something tax inspectors see in many industries. Football is a high-profile example because players and managers are now treated as assets on the balance sheet, and their pay often runs through image-rights companies and offshore vehicles.
If HMRC sets a clear precedent here, every club with a wealthy owner will check its own pay arrangements. If it doesn’t, others may take that as a sign they can do the same.
The Bottom Line
HMRC began looking at Manchester City eight years ago, before the Premier League brought any charges. The commission has now done its part and the club is appealing. The question for HMRC is no longer whether it knew about the arrangement, but what it did once it knew. The Treasury Committee has asked, and the public deserves a straight answer. A tax authority that says it will be “relentless” with Premier League clubs needs to show it has acted against the biggest of them.
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