HMRC Is Pressed to Open Manchester City’s Tax File

Dame Meg Hillier has given HM Revenue and Customs until 15 October 2026 to say what it will do with Manchester City’s sham-contract findings. The Treasury Committee chair wrote to the tax authority on 1 October, two days after an independent commission found the club guilty of 114 of 115 Premier League charges covering 2009/10 to 2017/18.

The football case is about more than £900 million ($1.2 billion) of inflated income and hidden costs. The tax file now in front of HMRC is smaller, and it does not travel with a sporting appeal.

Hillier Asks HMRC If It Has Seen the Full File

Hillier, the Labour MP for Hackney South and Shoreditch, wrote to HMRC’s permanent secretary John-Paul Marks after the league published the commission’s findings on 29 September 2026. She flagged the passage on devices used to disguise “the true extent of certain club liabilities,” which the commission called shams, or deals that did not match the economic substance of what actually happened.

Leaked contracts from 2018 identify the redacted manager as Roberto Mancini, who ran City from 2009 to 2013 and now manages Italy. Hillier asked Marks for a reply by 15 October 2026 and said she would put both letters in the public domain.

While I acknowledge that taxpayer confidentiality may inhibit what you can disclose, I would welcome reassurance from HMRC that you are seized of the importance of these issues and the public interest in the case.

Dame Meg Hillier MP, chair, Treasury Committee, letter to John-Paul Marks, 1 October 2026

HILLIER’S QUESTIONS TO MARKS

• Awareness: Confirm that HMRC knows the commission’s findings, pending any appeal.
• The full file: Say whether HMRC has asked for, or been given, an unredacted copy of the report.
• Football work: Give an overview of current HMRC work on clubs, including tax on pay, and how the department is tackling common issues.

HMRC declined to say whether it has opened a file on the Mancini payments or on any other finding in the ruling, citing its usual rule against discussing identifiable taxpayers. City declined to comment on the tax memo when asked after the verdict.

Hidden Manager Pay Opens the Tax File

The Premier League said an independent commission found City guilty of all financial-rule charges across those nine seasons, and guilty on three of four charges of failing to co-operate. Richard Masters, the league’s chief executive, said the club “systematically broke Premier League Rules for nearly a decade.” Sanctions will be set at a later private hearing. City has until 2 October 2026 to appeal the findings.

The commission found that sponsors paid only part of the fees written into the deals, with Abu Dhabi United Group Investment and Development Ltd, the owner, funding the rest. That disguised funding ran to £830.69 million. Further sham deals, including a circular image-rights arrangement with an entity called Fordham, let the club show lower costs than it incurred. Taken together, the schemes inflated revenue and cut costs by more than £900 million, so the club appeared to meet spending limits.

That is a sporting problem. It is a weak tax story. Tax Policy Associates, a non-profit tax research group, says the income inflation is unlikely to have created a UK corporation-tax bill, and that City paid no corporation tax in the period because it was loss-making. The live tax risk is the other half of the ruling: costs that were moved off the UK payroll.

SPORTING FINDING VERSUS TAX EFFECT

The £8.866 million pot is the one TPA can reconstruct from leaked papers. The other two omitted pots, £7.4 million and £500,000, may raise the same PAYE questions, but the public file on those people is thinner.

How the Mancini Consultancy Was Paid

The published ruling redacts the manager’s name. TPA matches the redacted box to Mancini by the four-season span, the manager-contract rules that were breached, and the width of the blacked-out surname. Football Leaks papers from 2018 name him throughout, and the payments in that bundle add up to the £8,866,367 figure used by the commission. Neither Mancini nor the club has disputed that those documents are genuine.

THE SECOND CONTRACT, 2009 TO 2011

1. 19 December 2009: City signs heads of agreement with Mancini for a basic salary of £1.45 million a season, net of tax, so the club bears the UK bill on that contract.
2. 19 December 2009: Al Jazira Sports and Cultural Club, also owned by Sheikh Mansour, sends heads of agreement for a consultancy at £1.75 million a year, with no tax deducted, for a minimum of four days’ coaching in Abu Dhabi.
3. March 2010: The consultancy is signed with Sparkleglow Holdings Ltd, a Mauritian company, from 1 January 2010, plus a signing-on fee of £62,328.77, which is £1.75 million times 13 days, the gap from his City appointment to that start date.
4. 25 March 2011: Sparkleglow asks Al Jazira for the first £1,805,136.99. The sum is paid from a Barclays account in Manchester labelled MCFC Stadium Oper, authorised by City’s head of finance, not by Al Jazira.

When Mancini’s lawyer later wanted to renegotiate the consultancy, she wrote to Garry Cook, then City’s chief executive, not to Al Jazira. Cook treated the extra money as part of Mancini’s overall compensation and agreed a further sum to cover Italian tax. The commission’s conclusion was that the side deal was a sham, and that if that is wrong, City was still the party that had to pay, with ADUG paying on its behalf.

Days before the verdict, Mancini was asked about the old double-contract reports and said, “It is not my concern.” The commission has now made it the club’s concern, and Hillier has made it HMRC’s.

Unpaid PAYE Could Reach £24 Million

Dan Neidle, founder of Tax Policy Associates, published the group’s assessment on 1 October 2026. If the Al Jazira fees were really pay for work at City, they were employment earnings. City should have run them through UK PAYE and National Insurance in the same way as the £1.45 million net salary. TPA finds no sign that it did, and no settlement line in the club’s accounts.

The wages were net, so the UK tax the club would have had to bear is large relative to the cash Mancini received. TPA puts unpaid UK tax at around £12 million of unpaid UK tax. Interest to date is put at £7.0 million. A penalty at 35 to 50 percent adds £4.1 million to £5.8 million. The combined bill in that memo is £23 million to £24 million.

Manchester City cheated Premier League rules, the Commission found. Did it also cheat HMRC?

We've examined the decision and leaked Mancini documents. We think City likely failed to pay £12m in tax.

There should be a criminal investigation.

Thread: pic.twitter.com/NqhuJDCiWv

— Dan Neidle (@DanNeidle) October 1, 2026

THE MANCINI PAYE BILL IN THE MEMO

• Unpaid UK tax: Around £12 million of income tax and National Insurance, because the consultancy was written net.
• Interest: £7.0 million to date on that unpaid tax.
• Penalty range: £4.1 million to £5.8 million at 35 to 50 percent.
• Combined: £23 million to £24 million if HMRC assesses tax, interest and a penalty together.

TPA also works the annual arithmetic. Putting £1.75 million net through the UK payroll in 2011/12, when the top income-tax rate was 50 percent, would have cost City about £4.15 million including employer National Insurance. Routing it as an Italian consultancy cost about £3.19 million. Most of the gap is National Insurance, not the difference in income-tax rates. From 6 April 2011, disguised-remuneration rules also require an employer to operate PAYE when a third party pays an employee’s reward, with a group-company exception that does not apply where there is a tax-avoidance arrangement.

You can’t magically make a salary untaxed by calling it a consultancy fee. If the payments were really for Mr Mancini’s work at Manchester City, they were employment earnings and should have been taxed in the usual way.

Dan Neidle, founder, Tax Policy Associates, 1 October 2026

Neidle asked City whether it had accounted for UK tax properly and got no reply. He said he is not accusing named people of a crime, and that unpaid tax is not the same as tax evasion, which needs a dishonest attempt to evade. The question for investigators is whether relevant staff were dishonest, or whether they made an error.

False Accounts Raise a Companies Act Question

The PAYE number is the cleanest figure in the public tax file. The heavier legal language sits in the accounts. The commission found that City filed misstated accounts and hid the true state of its finances from its auditors and from football regulators. TPA says that finding, if it stands, suggests Companies Act criminal offences may have been committed. That is a company-law problem, not a Premier League one.

The published package is still thin. The league released a redacted 40-page core decision. TPA notes that the parties’ document index alone ran to 750 pages, and that the hearing transcripts ran to about 7,000 pages after a 42-day hearing that ended in December 2024. Hillier’s request for the unredacted text is the piece HMRC would need if it wants names, invoices and the other two hidden pots, not only the Mancini trail that leaked in 2018.

The Premier League began its investigation in December 2018 and issued a complaint in February 2023. Masters called the case the most significant disciplinary matter in the league’s history. None of that binds HMRC. Tax assessments, PAYE determinations and any criminal charging decision run on their own clocks, their own tests of dishonesty, and their own disclosure rules.

Downing Street Rows Back After Burnham Speaks

Prime Minister Andy Burnham, who was mayor of Greater Manchester until June, told the BBC on 30 September 2026 that he would be “really concerned to lose them,” meaning City’s owners, and called them “a huge partner in the building of modern Manchester.” He thanked City Football Group for money put into the Etihad campus and into the city, said he would not jump to a conclusion while the club still contests the findings, and said he would keep his distance if UAE officials sought talks.

Conservative critics called the tone a public defence of the owners. By 1 October a Downing Street spokesperson was restating the line in harder words, after Hillier’s letter had already landed.

As the prime minister made clear, the initial judgment is serious and there can’t be any suggestion that anyone is above the rules. He also stressed that it is an ongoing independent process. It is essential that it is allowed to run its course and the outcome respected. If wrongdoing is established, those responsible should face the appropriate consequences.

Downing Street spokesperson, 1 October 2026

Burnham cannot instruct HMRC, and Hillier does not need him to. The Treasury Committee oversees the tax authority. A letter on the parliamentary record, with a dated request for a reply, is how that oversight is exercised when a football verdict starts to read like a payroll case.

A Football Appeal Cannot Close a Tax Case

City says it is innocent of the accusations and will appeal on the basis that the opinion contains “clear material errors, of law, principle and fact, and is unsafe.” Chairman Khaldoon Al Mubarak has told supporters the club will clear its name. The expected appeal line on sponsorship is that money came from the Abu Dhabi government, including the Crown Prince Court, rather than from ADUG. The commission already heard that account and called it an explanation “concocted well after the event.” Etihad Airways, the club’s principal sponsor, has said it is considering legal action over the published findings and rejects any implication of improper deals.

Even a successful sporting appeal would not rewrite the bank trail TPA set out. A City account paid Sparkleglow. Cook treated the consultancy as compensation. The commission, on the evidence it accepted, called the device a sham. HMRC can recast pay on those facts whether or not an Appeal Board later trims a charge list or a sanction.

WHAT WE KNOW

• The verdict: City was found guilty of 114 of 115 charges, including every financial-rule charge for 2009/10 to 2017/18.
• The tax memo: TPA estimates around £12 million of unpaid UK tax on the Mancini consultancy, and £23 million to £24 million with interest and penalties.
• The parliamentary clock: Marks has been asked to reply by 15 October 2026.

WHAT IS UNCONFIRMED

• An HMRC file: The department will not say whether a taxpayer inquiry is open, closed or was never started.
• Other hidden pots: Public papers do not yet show whether the £7.4 million and £500,000 omissions were run through UK payroll.
• Sanctions: No sporting penalty has been imposed, and the appeal window runs to 2 October 2026.

Hillier did not ask Marks to strip titles. She asked whether Britain’s tax authority has the unredacted decision, and whether it is treating hidden football pay as a tax problem. The answer is due on 15 October 2026.

Disclaimer: This article is news reporting and analysis of a Premier League ruling, a parliamentary letter and a published tax assessment. It is for information only and is not tax, legal or accounting advice, and it is not a finding that Manchester City, Roberto Mancini or any named person committed a tax or company-law offence. Readers who need advice on PAYE, National Insurance, company accounts or criminal exposure should consult a qualified tax adviser or solicitor before acting. Figures, charges and process dates reflect the sources cited as of 2 October 2026 and may change if HMRC replies, if the club appeals, or if later rulings alter the findings.