This summer’s transfer window demonstrated the Premier League’s enormous financial muscle, with clubs spending almost £3.5 billion on transfer fees across the period.
A notable feature of this window was the high volume of significant transfers conducted between Premier League clubs themselves, a pattern that stands out against previous years.
While the Manchester City case has made most football observers familiar with profit and sustainability rules, a separate tax-related factor may also be shaping recruitment decisions.
The question being asked by tax professionals is whether the abolition of the Remittance Basis in April 2025 is quietly discouraging overseas-based players from moving to England.
Under the previous regime, players at top clubs competing in European competition could claim Overseas Workday Relief, allowing a proportion of their salary to be exempt from UK tax for up to three tax years.
As an example, a player who competed ten per cent of their games overseas could exempt ten per cent of their salary from UK tax, subject to certain conditions.
Players could also shelter non-UK income and gains from UK tax for up to fifteen years under the Remittance Basis, provided those funds were not brought into the UK.
The new Foreign Income and Gains regime, introduced from 6 April 2025, replaced these arrangements and brought significant changes that alter the calculus for incoming players.
The FIG regime offers a full exemption on non-UK income and gains, which is technically more generous than the Remittance Basis, but it is only available for four tax years, likely covering just three playing seasons.
Overseas Workday Relief has been extended to four tax years, but is now capped at £300,000 per year, a limit that is largely meaningless for top-flight players earning well in excess of that amount every week.
Adam Jefferies, a director at PKF Littlejohn, argues that for players who have already accumulated significant wealth, the FIG regime does not provide the medium-term tax benefits that the Remittance Basis previously afforded.
“For footballers, having consistency with their tax position is extremely important, especially as they only have a relatively short career to earn these levels of income,” Jefferies notes.
It is not a stretch, as Jefferies observes, to think that a newly recruited footballer from outside the UK will have an eye on the end of the FIG regime and be looking to move abroad after three seasons.
This short-term horizon could help explain the unusual volume of high-value transfers between Premier League clubs this summer, as teams look domestically rather than internationally.
The rise of British players moving abroad to countries with attractive tax regimes, including Saudi Arabia and Italy, adds another dimension to this shifting landscape.
Jefferies raises the question of whether a relaxation of recently introduced rules could be considered to keep the Premier League competitive as a global force, particularly given the negative attention surrounding the Manchester City case.
Public sympathy for highly paid footballers is unlikely to be forthcoming, but the financial and reputational stakes for English football may yet force policymakers to revisit these changes.