Payments of agency fees made on behalf of a professional footballer to his agent were not deductible under the tax provisions for general expenses or under the provisions for agency fees paid by entertainers, and late tax return filing penalties were upheld. 

Summary 

Payments of agency fees made on behalf of a professional footballer to his agent were not deductible under the tax provisions for general expenses or under the provisions for agency fees paid by entertainers, and late tax return filing penalties were upheld. 

Background 

The appellant, a professional football player, was at all relevant times employed by Everton Football Club (Everton). He joined Everton from FC Lokomotiv Moscow on 1 February 2016. The appellant had entered into a ‘representation contract’ with an agent (IR). The contract provided (among other things) that the consideration payable by