Research by the Guardian and the Tax Justice Network reveals 28 English clubs with substantial shareholdings overseas, opening up the football leagues to criticism for allowing ownership structures that could be used for tax avoidance

Almost one in three of the 92 Premier and Football League clubs are now substantially owned overseas, including in offshore tax havens, leading to the English football leagues being accused of allowing ownership structures of clubs that could be used for tax avoidance. Research into the ownership of all the clubs by the Guardian and the campaign group the Tax Justice Network has found 28 clubs with a substantial shareholding overseas, including nine of the 20 Premier League clubs.

The Tax Justice Network, which has produced its own report, The Offshore Game, argues the ownership of football club shares via offshore companies means there is “huge potential for tax avoidance” when the clubs are sold. There is no suggestion any particular club or owner has engaged in tax avoidance; however, owners residing abroad, who hold shares in clubs through companies registered overseas, may not be liable for UK capital gains tax – currently 28% for higher rate, wealthier, tax payers – on the profits they make when they sell a club. The huge rise in offshore ownership of clubs, which were almost all UK-owned until the wave of overseas buyers moved in around a decade ago, has coincided with steepling increases in television rights and the value of clubs, in the Premier League, and in the Championship for clubs with a prospect of promotion. “The ownership of billions of pounds worth of assets through offshore shell companies means there is a huge potential for tax avoidance,” said George Turner, author of the Tax Justice Network’s report. “This should be of great concern to fans around the country, who invest so much time, commitment, emotion and money into their clubs.

“Football is not just another business and tax havens have no place in our national game, whatever the reason an owner may have for using them.”

While many of the clubs are not owned via shell companies and their locations reflect the nationalities of the businessmen who have bought the clubs – including Sheikh Mansour, the Abu Dhabi-based owner of Manchester City, the Malaysian owners of Queens Park Rangers and Venky’s, the Indian poultry company which owns Blackburn Rovers – other clubs are owned in a variety of countries widely recognised as tax havens. The Cayman Islands feature in the ownership of four clubs: Manchester United, now registered there; Birmingham City, Coventry City and Cheltenham Town.

United was re-registered in the Cayman Islands when the club was floated on the New York stock exchange in 2012, and company documents state the club is now owned by family trusts “affiliated” with the Glazer family, via companies registered in the US state of Nevada. United and the Glazers have never explained why they employ this structure and did not respond to questions about it from the Guardian.

Why are English clubs owned overseas? Their responses Read more

The American businessman Stan Kroenke holds his 66.8% of Arsenal via a corporation, KSE UK Inc, registered in Delaware, sometimes referred to as the tax haven state of the US, because of the anonymity it affords shareholders and its taxation laws.

The club declined to say whether this means no capital gains tax will be payable if Kroenke sells his stake at a profit but he has always been described as committed to owning Arsenal in the long term and not intending to sell.

Fenway Sports Group and Randy Lerner, the US owners of Liverpool and Aston Villa respectively, declined to say in which US state their ownership companies are registered. Ellis Short, the American owner of Sunderland, still owns the club via the Jersey company, Drumaville, which the previous Irish investors, associates of the former chairman Niall Quinn, used as their ownership vehicle. A Fulham spokesperson said Shahid Khan, the club’s American owner, will shortly fold the British Virgin Islands company previously owned by Mohamed Al Fayed, and the ownership structure will become fully UK-based.

Other countries where English clubs are owned, generally classed as tax havens because of their low tax rates and corporate anonymity for shareholders, include Bermuda, the Bahamas, Jersey, the Isle of Man, the West Indies, Luxembourg and Guernsey. The clubs owned in these jurisdictions range from the very richest, including Tottenham Hotspur – ultimately owned by Joe Lewis in the Bahamas – to some of the smallest, including Cheltenham, Shrewsbury Town, and Southend United, where a substantial shareholder is Mezcal Investments, a company listed in the BVI company register.

Prem Sikka, professor of accounting at the University of Essex, said that besides the capital gains tax saving, there can also be tax advantages if the offshore owner makes loans, on which the club pays interest from the UK.

“These clubs were at the heart of their local communities and still have that tribal following, so should be rooted there,” Sikka said. “If the local ownership is removed, they cease to be clubs; they’re just businesses.”

Richard Murphy, director of Tax Research UK, said even where clubs are owned by overseas investors who have put money into their clubs, much of the additional value comes from local fans and TV subscribers paying high prices but the owners’ wealth and capital accumulates offshore.

“Football clubs are being used as speculative business opportunities,” Murphy said.

The Premier League and Football League did not directly respond to the criticism that the use of offshore tax havens and countries overseas to own locally-rooted clubs enables capital gains tax to be avoided. The Premier League stressed that all club-companies, if not the vehicles which own them, must be registered in the UK so are subject to corporation tax if they make profits.

Manchester United fans campaigning against the Glazers’ takeover have long pointed out the £525m debt imposed by the 2005 acquisition, and steepling interest paid by the club, wiped out United’s profits for years, so led to no corporation tax being paid.

The Premier League also repeatedly stresses the amount of PAYE tax its clubs pay, given the huge wages paid to top players – some of it due to overseas owners’ investment – and the upper income tax rate of 45% – £1.3bn was paid in taxes last year, the league said.

“In most cases where clubs’ parent companies are registered overseas, this reflects their owners’ nationality or domicile and the source of the original investment in the club,” a Premier League spokesman said. He stressed that they do not have a problem with secrecy because the league insists on being shown who clubs’ owners are.

“It is clear that overseas investment has been good for the development of the English game,” the spokesman said.

The Football League requires club owners to pass the test formerly known as “fit and proper,” and to show they have the necessary funding to keep a club competing, but a spokesman said the league is “neutral” on how a club’s ownership is structured. He also pointed to article 63 of the Treaty on the Functioning of the European Union which enshrines free movement of capital between EU states and other countries, suggesting that makes offshore ownership difficult to prevent.

Damian Collins, the Conservative MP who last year submitted a Football Governance bill to parliament, argues that capital gains tax should be made payable on the sale of football clubs, as it will be under a new law when overseas owners sell UK residential property.

Robin Osterley, the chief executive of Supporters Direct, which encourages fan ownership and involvement in the running of clubs, said it is “very concerning” so many clubs are owned offshore. He said: “This clearly creates golden opportunities to avoid paying taxes in the UK, and increases the lack of transparency and potential for obfuscation about ownership which is so harmful to the interests of the game,.

Football’s 92 clubs and four professional divisions have long been a kind of English monument, broadcasting the names of their towns and cities for almost 100 years. This is a very modern phenomenon, of the 21st century British economy, that their ownership now entails a cruise around the tax havens of the world.