Editorial March 2025 issue of Sports Law & Taxation

It is with much pleasure that we welcome readers to the March 2025 edition (citation: SLT 2025/1) of our ground-breaking journal Sports Law and Taxation (SLT) and online database https://sportslawandtaxation.com.

As usual, association football continues to dominate – both on and off the pitch – the sporting headlines.

2025 winter football transfer window

The 2025 winter football transfer window has come and gone, with the English Premier League and the Women’s Super League contributing to the record figures spent. Almost £ 1.9 billion was spent globally by clubs, an all-time high for this window. Clubs in England accounted for more than 25% spent in the men’s game amounting to £ 498 million, with Manchester City having the biggest spend of around £ 190 million. German clubs were in second place, with a spend of £ 237 million, followed by Italy, France and Saudi Arabia, with spends of £ 178 million, £ 167 million and £ 162 million respectively.

In the men’s game, the total spend was almost 20% higher than the previous record of January 2024. However, the English Premier League total spend in January 2025 of £ 370 million was way behind their record spend of £ 815 million in January 2023.

In the women’s game, there was a record spend of £ 4.65 million, which was up by 180.6% on last year’s record. Chelsea set a new world record with their signing for £ 900,000 of US defender, Naomi Girma, from San Diego Wave. French clubs were in second place, with a spend of £ 860,000, followed by the USA and Germany, with spends of £ 702,000 and £ 298,000 respectively.

Deloitte Football Money League 2025

On 23 January 2025, Deloitte, a leading multinational services group, which is based in London, United Kingdom, published its latest Football Money League Report. Now in its 28th edition, it profiles the highest revenue generating football clubs in world football. Highlights of this Report now follow.

Ground control

The 2023-102424 season created football history, as Real Madrid became the first football club to generate € 1 billion across a single season. The club’s financial success during the season was underpinned by the newly renovated and expanded Bernabéu Stadium, which delivered significant uplifts to matchday and commercial revenue over the previous season.

Cumulatively, the Money League clubs in 2023-2024 generated a record € 11.2 billion, an increase of 6% over the 2022-2023 season, with record matchday, commercial and broadcast revenues.

In 2023-2024, the average Money League club generated € 560 million, comprised of € 244 million (44%) commercial revenue, € 213 million (38%) broadcast revenue, and € 103 million (18%) matchday revenue.

A rise in clubs’ stadium capacity, general ticket prices and premium matchday offerings caused matchday revenues to grow 11% year-on-year, making it the fastest growing revenue stream for Money League clubs once again. Matchday revenue surpassed € 2 billion (€ 2.1 billion) for the first time in the history of the publication, accounting for 18% of total revenue, the highest share since 2014-2015 – 19%.

Revenue generated by 2025 Money League clubs was € 11.2 billion. Growth on revenue generated by 2024 Money League clubs was 6%.

At € 4.9 billion, commercial remained the largest revenue source for Money League clubs for the second year running, accounting for 44% of total revenue. The 10% uplift over the previous year was largely driven by an increase in the hosting of non-football live events, improved retail performance and a rise in sponsorship revenues.

During the 2023-2024 season, several football clubs hosted major sporting events in their stadia, boosting commercial revenues. For instance, select French clubs benefitted from the 2023 Rugby World Cup and German clubs from the 2024 UEFA EUROs. Recognition of the reliability and potential upside from venue-generated income has led to half of the Money League clubs pursuing stadia redevelopment in 2025, including FC Barcelona and Manchester City (presently in the construction phase) and Manchester United (currently exploring available options to redevelop Old Trafford).

Additionally, eight Money League clubs reported stronger retail performance, highlighting their ability to leverage brand value and sporting success to drive commercial revenue and likely a move towards clubs controlling more of the value chain from the sale of merchandising than ever before – perhaps a sign of how the business model of football clubs is evolving for the future.

In contrast, there was no uplift in the broadcast revenue (€ 4.3 billion) cumulatively reported by Money League clubs in 2023-2024, as each of the “big five” leagues remained in the same domestic broadcast cycle as the preceding season. The “big five” leagues have entered or will be entering a period of relatively stable broadcast revenues due to longer-term domestic media rights deals through to at least 2027. The Premier League will reportedly benefit from an uplift in the value of its international media rights from 2025-2026, primarily through new agreements across the MENA and APAC regions. Furthermore, in November 2024 the Premier League announced plans to establish an in-house media operation, signalling a potential evolution to its business model. Launching in 2026-2027, this initiative will be responsible for the production and distribution of international media, potentially reshaping the league’s relationship with broadcast partners.

Average matchday, broadcast and commercial revenue generated by Money League clubs 2017 to 2024

There is a clear distinction in revenue generation models between the two halves of the 2023-2024 Money League. For clubs ranked in the top 10, commercial revenue is the dominant income source, accounting for 48% of club revenues. Contrastingly, broadcast is the key revenue driver for clubs ranked 11-20, representing 47% of club revenues. Both sets of clubs respectively generated 18% of their total revenue from matchday.

The trend for the most financially successful clubs to leverage the growth in commercial revenue is illustrated by the evolution of the split between the different revenue streams. In 2009-2010, the revenue profile of the clubs ranked 1-10 and 11-20 was largely the same. Matchday accounted for 26% and 23% of total revenues across each group respectively, broadcast 43% and 44%, and commercial 31% and 33%. This indicates that, historically, business models of Money League clubs were relatively similar, with on-pitch performance driving financial success. While, 14 years on, this seemingly remains the case for clubs ranked 11-20, the same can’t be said for clubs ranked 1-10. In 2023-2024, the top 10 clubs’ revenue composition was more heavily skewed towards commercial revenue, ultimately driving differences in the significance of this (1-10: 48%; 11-20: 34%) and broadcast (1-10: 34%; 11-20: 47%) for clubs at either end of the Money League.

This indicates that while several Money League clubs leverage their global profile to drive club revenues, notably sponsorship and retail, several clubs, particularly those in the lower half of the Money League, are still reliant on on-pitch success. Since the 2016-2017 season, while only 11 clubs have featured in the top-10 of the Money League, 18 different clubs featured in the bottom half.

Club analysis

Real Madrid became the first football club to generate over € 1 billion in revenue during the 2023-2024 season and are at the top of the 2025 Money League. The completion of renovation works to the Bernabéu Stadium catalysed the growth of matchday revenues to € 248 million in 2023-2024, a 103% uplift on the previous year. The increase was realised predominantly on account of the marketing of personal seat licenses[1], which provided an uplift of circa € 76 million, as well as the sale of new VIP seats and the increased capacity of the stadium from December 2023. The club also reported a 20% increase in commercial revenue (from € 403 million to € 482 million), boosted by increased merchandise and new sleeve sponsorship.

Manchester City remained the highest revenue generating English club, with revenue of € 838 million. The gap between the top-two Money League clubs in 2023-2024 was € 208 million, the highest on record (previous record: € 84 million in 2018-2019).

Several clubs identified the impact of infrastructure investments as a key driver of revenue. For instance, Liverpool (€ 715 million) and Olympique Lyonnais (€ 264 million) benefited from such projects, with higher attendances and non-matchday events boosting matchday and commercial revenue respectively. Elsewhere, FC Barcelona fell to 6th following a decrease of € 40 million in revenue, from € 800 million in 2022-2023 to € 760 million in 2023-2024. The decline was driven by a € 63 million fall in matchday revenue due to matches being played at the Estadi Olímpic Lluís Companys, a stadium with nearly half the capacity of Spotify Camp Nou that is currently under redevelopment. However, with the club expected to return to the Spotify Camp Nou in 2025 (with the full stadium works to be completed before the 2026-2027 season), it will expect to reap the benefits of enhanced matchday and commercial revenues in upcoming seasons.

Women’s clubs

The Money League 2025 for women’s clubs consists of 15 of the highest revenue generating women’s clubs in some of the game’s leading markets.

Four of the top-10 Money League clubs identified retail and sponsorship as key revenue drivers in 2023-2024. The ability to generate incremental commercial revenue in recent years through brand activation has enabled the likes of Tottenham Hotspur and Liverpool to maintain their top-10 status, and AC Milan to retain 13th place despite missing out on lucrative UEFA Champions League broadcast income. Olympique Lyonnais also successfully monetised its brand, generating a € 27 million lump-sum royalty as compensation for granting of an initial 50-year license for the “Olympique Lyonnais” brands to OL Féminin.

Sporting performance

Akin to previous years, sporting performance played a crucial role in providing financial impetus. In the 2023-2024 season, this led clubs such as Arsenal (€ 717 million), Borussia Dortmund (€ 514 million), Newcastle (€ 372 million) and Aston Villa (€ 310 million) to grow revenues through participation in UEFA competitions and improved domestic performances yielding higher broadcast distributions. Contrastingly, Juventus (€ 356 million) fell from 11th to 16th, the club’s lowest ranking in Money League history, following an absence from European football in 2023-2024. The club reported an 18% decrease in overall revenue, following a 37% (€ 58 million) fall in broadcast revenue.

The make-up of the clubs ranked 11th-20th reinforces the impact of on-pitch success on financial performance. For example, Eintracht Frankfurt (€ 245 million) dropped out of the top-20 in 2023-2024 following a 34% decline in broadcast revenue (16% decrease in total revenue) as the club participated in the UEFA Europa Conference League versus the Champions League. This feat further underscores the distinction in business models between clubs in the Money League and reiterates the role commercial revenue generating ability has played in enabling the likes of Liverpool, Tottenham Hotspur, and Chelsea to retain their position in the top-10 despite reduced broadcast income after missing out on Champions League participation.

Future outlook

According to Deloitte analysis, over 300 sport stadium projects (renovations or new builds) are underway globally in 2025. While not all these projects relate to football clubs, it is reflective of an increased industry-wide focus towards creating stable and diversified revenue streams through stadia utilised beyond matchdays. In addition to increasing capacity to service excess demand, clubs are focused on building smarter entertainment destinations that deliver better experiences for players, artists, fans, and the wider community throughout the year. However, stadiums, much like the broader football club, are viewed as community assets and thus it is essential that they are built with the needs and welfare of the local community in mind.

Additionally, the “big five” European leagues are entering a period of stability in domestic broadcast income, and only the Premier League and LaLiga are expected to deliver significant uplifts through international rights. Therefore, the next material uplift could come from an increase in the number of matches played by clubs via the introduction of new formats to existing competitions. This can be expected on account of changes made to UEFA club competitions from 2024-2025, and the expanded FIFA Club World Cup between June and July 2025.

In financial terms, the expanded UEFA competitions will increase the revenue generating capacity of European clubs outside of the “big five” leagues, with more teams qualifying for the league phase, where they will play more matches. Per Deloitte analysis, excluding the impact of changes to the number of pre-knock out matches, winning the Champions League could result in revenue uplifts of circa € 15 million over the previous format (UEFA Europa League circa € 8 million and UEFA Europa Conference League circa € 3 million). Similarly, the FIFA Club World Cup is expected to provide a significant uplift to some non-European clubs such as Flamengo, who this year ranked in the top-30 of the Money League for the first time since 1996-1997 and Inter Miami.

However, there is a need to balance revenue optimisation with player welfare as many stakeholders acknowledge the impact of increased workloads. Clubs such as Real Madrid, Manchester City and Flamengo who are participating in the FIFA Club World Cup in 2025 could have potentially played in 68, 74, and 87 matches respectively during the 2024-2025 season.[2]

In October 2024, FIFPro Europe filed a formal complaint to the European Union over the international match calendar. Should the challenges not be resolved, there exists a financial risk if the Union votes to implement a strike during the football season. In addition, the need to manage workload is critical to providing the best on-pitch quality and the entertainment that fans, broadcasters, sponsors, and investors all crave. The inability to resolve this key challenge will damage the value of the sport in all senses in the long-term.

As governing bodies introduce new competitions or implement format changes to existing competitions, the relative importance of sporting performances in driving financial success for clubs will increase. The top performing Money League clubs have all used historical and current on-pitch success as a catalyst to spark the growth of global sport and entertainment brands. A shake-up in the rankings will require clubs further down the ladder to take the leap in on-pitch performance, while nurturing a brand and ethos that transcends borders to resonate with international audiences both in roaring stadiums and across digital platforms.

Women’s football in Switzerland

In the last several years, women’s professional football has continued to grow in popularity and claim fans in many parts of the world, not least in Europe, including Switzerland. It is a far cry from earlier times when women were not allowed to compete in professional games and tournaments.

Nowadays, the women’s game goes from strength to strength with, as mentioned above, the recent world record set for the transfer of a woman player. Chelsea Women’s Football Club, the current leaders of the English Women’s Super League, after fighting off competition from Lyon, have agreed to pay a world record fee of around £ 900,000 (around CHF 1 million) to the US San Diego Wave Women’s Football Team for their 24-year-old defender, Naomi Girma. Her new Chelsea contract will run until the summer of 2029.

According to Dr. Lucien Valloni, a sports lawyer and managing partner of Valloni, Attorneys at Law, Zurich, Switzerland, and a contributor this journal and our website, women’s football is also popular in Switzerland, which will host the 14th edition of the UEFA Women’s Euro Tournament from 2-27 July 2025 at various venues, including Basel, Berne, Geneva and Zurich.

The top level of women’s football in Switzerland is the Swiss Women’s Super League (“SWSL”), which was established in 1970. FC Zurich Frauen in the last 10 years have been SWSL champions many times.

The top-ranked teams in the SWSL qualify for the UEFA Women’s Champions League.

The Swiss Women’s National Football Team represents Switzerland in international football tournaments and first played in 1972. The team qualified for the 2015 and 2023 World Cups and the Euros 2017 and 2022.

The Switzerland Team Coach, Pia Sundhage, is excited about her team’s prospects in the 2025 Euro Tournament, and this is certainly a sports event to look forward to later in the year.

New life after sport!

We now turn to another topic which not only affects football but other professional sports as well!

It is a well-known fact that the careers of elite sportspersons are relatively short compared with those of other professionals. For example, football players, on average, retire between the ages of 31 and 35, and reach their peak performances between the ages of 25 and 27. The vexed question then is: what to do next?

For many, moving away from their sports marks the beginning of an entirely new and uncertain and, possibly, risky journey. Following years of dedication, intense training, and competitive success makes the transition into life after sport challenging, to say the least. To make this change as smooth and fulfilling as possible, careful consideration needs to be given to the need for financial security, personal growth, and the development of new interests.

A successful transition starts long before sportspersons take part in their final competitive events. Although sports careers demand intense focus and attention, it is advisable for sportspersons to explore potential passions and career paths early on in their sporting careers. Education, workshops, and hands-on experience in different fields offer new skills and a broader perspective on future opportunities. Building a network outside the sports world also opens up invaluable support and connections, making the process of entering a new professional sphere less daunting and more successful.

By redefining identity and purpose beyond sport, sportspersons can find fulfilment in roles in which they can inspire or lead others, such as mentoring or coaching the next generation of sportspersons. Others may feel drawn to community work, philanthropic pursuits, or starting businesses that reflect their personal interests and values. For example, George Foreman, the former American professional boxer, became a successful entrepreneur and known for his George Foreman grill, of which he sold more than 100 million worldwide. He later sold the commercial rights to the grill for the sum of US$ 138 million!

A successful sportsperson’s most valuable assets post-retirement are their personal brands. Although their competitive sporting careers may have come to an end, their reputations and stories continue to carry lasting power and resonate with fans and clients. For example, in 2018, the well-known English former footballer and England captain, David Beckham, launched his own fashion brand “House 99”, and also has established himself as a modern men’s style icon.

To leverage their well-earned personal brands after retiring from sport, sportspersons need expert financial, commercial and legal advice, especially on protecting their intellectual property rights. Amongst such specialist advisers is Athena Constantinou, managing director of APC Sports Consulting, Nicosia, Cyprus, one of our contributors to this journal and our website.

United States: transgender women sport ban

It will not, we think, have escaped our readers’ attention that there has been a change of guard in Washington with the return of president Donald Trump, who has already issued a barrage of Executive Orders on a wide range of subjects, including sport! It is reported that he has signed an Executive Order that bans transgender women from competing in female sports. The Order came into effect immediately and applies to high school, universities and grass root sports. Also, the Order is in line with a separate Order that president Trump signed on his first day in office on 20 January 2025 and which called for the US Federal Government to define officially sex as either being male or female. Needless to say, the latest Order has not gone down well with LGBT and human rights groups, who have characterised it as being discriminatory.

Furthermore, president Trump has stated that the Order will apply to the 2028 Summer Olympic Games, due to take place in Los Angeles, and that he will deny visas for transgender Olympic athletes wishing to participate in them. He has also stated that, during the Los Angeles Games, “my administration will not stand by and watch men beat and batter female athletes.” Fighting talk, characteristic of the new president, indeed!

Articles in this issue

We now turn our attention to some of the articles, which we publish in this issue of SLT.

On the sports law side, we would draw the particular attention of our readers to the article by Abhinav Tigga on the doping case of tennis player Simona Halep, who, incidentally, has recently announced her retirement from the professional game. In his introductory remarks, Tigga writes as follows:

“The Court of Arbitration for Sport (“CAS”) has finally released its reasoned Award on the doping charges against Simona Halep, the Romanian professional tennis player. Her initial sanction of four years was reduced to a nine month period by the panel. Since the former world number one had already served a provisional suspension of that length, she is now free to compete.

Tennis fans, being the romantics they are, lauded the decision, whilst criticising the delay in proceedings for hindering Halep’s career. Doping violations lacking intent, or where no fault or negligence is found, are generally viewed at the innocent end of the spectrum. People tend to forget that, underlying the infringement, lies the principle of strict liability, which still mandates a (lesser) degree of sanction. Nevertheless, fans cannot be blamed for overlooking the need for fairness and a level playing field when the alleged violator is a former Wimbledon and French Open champion.

However, this article is not about the public perception of the doping framework, where an athlete’s consumption due to contamination is ruled unintentional. The article instead focuses on CAS jurisprudence relating to the Athlete Biological Passport (“ABP”) and the possible ramifications of the decision clearing Halep.”

And he concludes his article as follows:

“There is no doubt that this award has the potential to steer CAS ABP jurisprudence in a new direction. Defence lawyers representing athletes will certainly welcome this precedent, as it would be the first to rebut successfully a doping scenario. When athletes had previously used a variety of explanations, experts responded arguing that such cases rarely reach a threshold fluctuation that would cause a passport to be declared abnormal. Halep’s strategy could become a useful reference for defence lawyers (and experts) aiming to establish similar factual and technical profiles in combating ABP allegations.

That said, replicating the unique circumstances of Halep’s case could prove to be an uphill task. Her defence was strategically focused on emphasising the sample closest to the competition schedule. The invalidity of that ABP sample, coupled with the timely substitution of private results, was a fortunate development. Nevertheless, significant effort was still required to present these private results credibly, backed by detailed evidence to establish their authenticity.

The case highlights the pivotal role experts play in ABP cases. While doping cases generally depend on expert testimony, ABP disputes require an even higher level of expertise. Athletes may always consult experts before pursuing an appeal to determine which physiological or pathological explanation best aligns with their HGB/RET% fluctuations. Although numerous studies exist on ABP, CAS adopts a highly selective approach in choosing which to consider. This selectivity applies not only to the ABP literature, but also to the experts. They must possess the necessary credentials. In fact, CAS arbitrators have emphasised that they do not attempt to assume the role of the expert. Their task is limited to evaluating the evidence presented, whilst also weighing the testifying expert’s credibility based on qualifications and experience. The complexities of ABP can be difficult to assess without specialized training.”

We would also draw the attention of our readers to the article by Dr. Estelle Ivanova on the regulation of sport in France. She introduces this interesting and complex subject as follows:

“France has a rich sporting heritage and places great importance on the governance of sport, ensuring accessibility, social inclusion, and ethical standards. However, sports regulation in France is complex, shaped by legal frameworks, historical developments, and the interplay between public and private stakeholders.

This article provides a focused analysis of key aspects of French sports regulation, specifically governance structures and dispute resolution mechanisms.

Whilst this article is limited to French law, sports regulation is influenced by European Union (EU) law, the European Convention on Human Rights (ECHR), and international obligations, necessitating ongoing regulatory adaptation. Ensuring the integrity of sports governance is crucial to maintaining fair competition, protecting athletes’ rights, preventing corruption, and upholding ethical standards.

In France, sports regulation is based on constitutional principles, legislative acts, governmental decrees, federations’ statutes, regulations, and contracts. Each stakeholder plays a role in shaping this evolving regulatory framework. By examining stakeholders’ roles and dispute resolution mechanisms, this article highlights the key challenges and the evolving nature of sports regulation in France.”

And she reaches the following conclusions:

“Sports regulation in France operates within a multi-tiered legal framework that balances state intervention, federation autonomy, and the role of independent regulatory authorities.

However, evolving challenges, such as digitalisation, the growing commercialisation of sport, and ethical concerns, require continuous regulatory adaptation.

Strengthening dispute resolution mechanisms, reinforcing governance integrity, and ensuring accessibility will be crucial in maintaining a fair and sustainable regulatory framework.

As French sports law continues to evolve, its ability to balance legal certainty, institutional autonomy, and international influence will shape the future of sports governance in France.”

On the sports tax side, we would mention, in particular, the article by Kevin Offer with the intriguing title “Professional Game Match Officials Limited (PGMOL) – The final whistle? – Well, almost!” He writes in his introduction as follows:

“This journal has been following the UK case considering the employment status of football referees through the various courts. To date, it has not been clear what the final decision would be, and, after the latest judgement of the Supreme Court, there is still no final result. It could be said, however, that we are moving towards penalties to find a winner.”

And after chronicling the twists and turns of this important case through the UK Tax Tribunals and the Court of Appeal (CoA) and the Supreme Court (SC), he reaches the following conclusions:

“The question of whether an individual is employed under a contract of service or self-employed under a contract for services has occupied the time of the Courts on a number of occasions and still presents difficulties. The PGMOL case was decided by the “experts” at the FTT in favour of the referees, but the CoA were very critical of that decision. The SC concurred with the CoA, and it has been noted that the first two conditions established in the RMC case should not be given as much importance as the third test. Unfortunately, however, the SC has not considered that condition as it did not need to do so to determine that the appeal should fail.

The personal view of the author of this article is that the CoA and SC decisions are an indication that the FTT should now find in favour of HMRC, but it will be up to the FTT to consider the overall position of the referees and determine whether the contracts constitute employment contracts. This may include consideration of other, non-tax matters, such as employment rights.

In addition, by referring the matter back to the FTT, HMRC will consider that the final decision will not create a precedent for future cases as FTT decisions are not binding on other tribunals.

This case is important in considering the difference between employment and self-employment across the board and, therefore, HMRC will wish to be able to take other cases as and when they see fit.

Thus, the question of whether referees are employees of PGMOL has yet to be concluded but a final decision in this case should follow from the FTT.

Maybe not another replay or even extra-time but we are perhaps moving towards penalties!”

We would also draw attention to the article by Virginia Cirera on an important ruling on tax residency in Spain involving the football player, Luka Modrić. She introduces the subject as follows:

“It has been reported by the Spanish media that Real Madrid player Luka Modrić will be reimbursed € 2.7 million after winning his case against the Spanish tax authorities in a procedure regarding his taxes corresponding to the year 2012.

This favourable ruling has been perceived as positive by other football players, clubs and advisors, who are currently under the scrutiny of the tax authorities for similar reasons.

It is not a secret that elite athletes, and particularly football players, have been targeted for tax audits and that the pressure is exacerbated by the fact that the tax authorities tend to use these types of cases to set an example of its fight against tax fraud.”

And she concludes her article with the following observations:

“Determining the football player’s tax residence, therefore, should be a priority in any international transfer agreement, as it affects not only the player but also other stakeholders, like the club, agent and advisors.

An incorrect determination can lead to long and costly disputes with the tax authorities, but it can also put a player’s reputation at risk by exposing his or her name to the media as an alleged tax evader.

On the other hand, rulings such as Modrić’s give advisors the strength to continue defending the player’s interests and, why not, to look for loopholes in the law.”

As you will see from the Table of Contents of this issue, we include, in addition to the articles highlighted above, a wide range of topical sports law and sports tax articles, which, we believe, will, again, engage our readers’ attention and provide them with much “food for thought”.

As always, we would welcome and value our readers’ contributions in the form of articles and topical case notes and commentaries for our journal and also for posting on the SLT dedicated website https://sportslawandtaxation.com, which continues to go from strength to strength and covers important sports legal and tax developments and issues.

So, now read on and enjoy the March 2025 edition of SLT.

Dr. Rijkele Betten (Managing Editor)

Prof. Dr. Ian S. Blackshaw (Consulting Editor)

March 2025

[1] Holders of Personal Seat Licenses are entitled to buy season tickets each year for a certain seat during a period of 30 years.

[2] Includes four matches for the FIFA Club World scheduled to take place prior to 1 July 2025.