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Geovanni Deiberson Mauricio Gomez, best known only as Geovanni, left behind a magical legacy when he departed Hull City at the end of the 2009-10 season.

As well as scoring the club’s first Premier League goal on an unforgettable City debut against Fulham, the mercurial Brazilian went on to find the net away at Arsenal, Tottenham, Manchester United and Liverpool.

Memories of Geovanni’s time with the Tigers can still bring a smile to the faces of supporters a decade on from his final appearance, but for City’s current hierarchy it is a union that has caused lasting headaches.

A long-running legal wrangle between City and Her Majesty’s Revenue & Customs (HMRC) has Geovanni at its centre.

The issue surrounds the payment of £440,800 to Joniere Limited, an offshore company based in the British Virgin Islands, between December 2008 and July 2010.

(Image: Getty)

City have always maintained that the sum was justifiably paid to cover an image rights agreement for Geovanni but HMRC successfully countered that by claiming the outlay was “earnings for the purposes of PAYE and national insurance” and that the Tigers were therefore “liable to account for tax on that sum.”

City’s appeal against the original decision was heard in Manchester before the turn of this year and, after three days of legal debate and witness statements, was ultimately dismissed.

An HMRC spokesperson said: “We are pleased the tribunal has agreed [PAYE] tax should have been paid on the payments made as they were not made under a genuine commercial image rights agreement.”

This case is one that the Allam family considered to be a skeleton in the cupboard when taking charge of City in late 2010. By that point Geovanni had moved on to MLS side San Jose Earthquakes but the Tigers were soon asked to explain why such an amount had been paid to cover the image rights of a player with a seemingly limited international appeal.

(Image: Getty)

The use of image rights agreements by Premier League clubs was considered to be “commonplace” in 2007, with some of the top clubs having as many as 20 players tied up to such deals.

Expert evidence, though, argued that a club such as City “would not be expected to have the experience, resources or ability to exploit the commercial opportunities associated with players’ image rights.”

Tellingly, it added that “historically, image rights agreements had been used by some Premier League clubs and players as a means of disguising employment income to gain tax advantages.”

A 31-page record of the appeal hearing between City and HMRC was released last month and revealed every detail of the deal that made Geovanni City’s marquee signing in the aftermath of winning promotion through the 2008 Championship play-off final.

Geovanni’s basic wage during his first season at the KCOM Stadium was £14,400 per week. The former Barcelona and Manchester City man was also paid £500 per appearance, an accommodation expense of £4,000 a month and a £100,000 bonus if City avoided relegation from the Premier League.

Former chairman Paul Duffen, giving evidence at the appeal in October, said that those terms would have been negotiated by Phil Brown, manager at the time, and that he, as chairman, would have “simply been asked to approve it, which he did.” City also paid £450,000 to an agent to secure the Geovanni's signature.

Included in the player’s initial contract was an agreement for City to pay £187,200 per annum – exactly 25 per cent of his annual salary – to an image rights company.

The was Joniere Limited, based 6,000 miles away in the British Virgin Islands. Duffen told the hearing that he had no contact with Joniere in relation to the Image Rights Agreement but understood that it would give City the exclusive right to “use” Geovanni for promotional purposes globally. The agreement, though, did not cover the attacker’s image rights in the UK.

City had previously entered into an image rights agreement with Jay Jay Okocha, signed the previous season, and with Geovanni it was considered a “great idea” given the chance to exploit the player’s image in Latin America and the Far East to boost City’s own profile.

Those grand plans came to nothing and by the spring and summer of 2009, towards the back end of City’s debut season in the Premier League, it was said a “financial cloud was hanging over the club” after the principal backer – Russell Bartlett – encountered financial problems when a loan facility had been reduced from £20m to £15m by the club’s bank. It added that in August 2009 City had sold Michael Turner to Sunderland “to pay the wages.”

Nevertheless, City opted to extend Geovanni’s contract in September 2009 and increase wages substantially to £25,575 a week in a deal running until June 2011. Also on the rise was the amount paid to cover Geovanni’s image rights, climbing to £230,116 per annum.

The club’s relegation in May 2010 led to both Geovanni’s playing contract and image rights agreement being terminated that summer but HMRC continued to pursue City with an eye on the £440,800 paid to Joniere.

The case has since rumbled on and on. It was HMRC’s position in 2017 that “Joniere was effectively a nominee of the player, receiving sums that were legally due to the player himself.”

The burden was on City to prove that the money paid did not constitute earnings during the tribunal held in October of last year but the club’s legal team was unable to do so.

(Image: Getty)

Among the conclusions reached by Judge Jonathan Cannan was that “the club did not have any clearly defined intention or plan to commercially exploit Geovanni’s overseas image rights” and that “the club did not have the resources to exploit Geovanni’s overseas image rights even if there was a market to do so.”

“No one at the club could reasonably have believed that the rights had any commercial value,” the Judge added. “In reality payments to Joniere were a reward for Geovanni’s services as a footballer and formed part of his earnings.”

City’s appeal was dismissed but that does not necessarily mark the end of the case.

A statement from the club yesterday read: "With regards to the ongoing dispute with HMRC in reference to Geovanni’s image rights (whose contract predates the current ownership) the Club will continue to work with previous Directors in considering an appeal."