A comprehensive analysis demonstrating how Premier League regulations P7, P8, and Appendix 7 do not support charges against Manchester City regarding manager remuneration
*By A Special Correspondant*
The Premier League's case against Manchester City includes allegations concerning the remuneration of former manager Roberto Mancini, specifically claiming that the club failed to accurately report manager wages through an additional contract arrangement with Al Jazira FC in Abu Dhabi. However, a detailed examination of the actual Premier League rules cited in the charges, combined with analysis of the evidence and the Premier League's own official statement, reveals that this allegation represents a fundamental misapplication of regulations that simply do not address the type of arrangement in question.
## The Premier League's Official Position
The Premier League's official statement of 6 February 2023 provides crucial context for understanding the scope and nature of the charges against Manchester City [3]. The statement confirms that the Premier League has referred "a number of alleged breaches of the Premier League Rules by Manchester City Football Club (Club) to a Commission under Premier League Rule W.82.1."
Significantly, the statement details the specific rules that the club is alleged to have breached, and these provide important insights into the Premier League's interpretation of its own regulatory authority. The charges span multiple seasons from 2009/10 to 2017/18, with different rules cited for different periods, reflecting the evolution of the Premier League's regulatory framework over time.
For the Mancini-related allegations, the statement indicates that the charges relate to "accurate financial information" and "manager remuneration," but crucially, when examined against the actual text of the rules cited, it becomes clear that these regulations do not prohibit or regulate the type of arrangement that existed between Mancini and Al Jazira FC.
## The Fundamental Disconnect: No Wage Disclosure Requirements in Cited Rules
Before examining the specific content of the Premier League rules cited in the charges, it is essential to establish a fundamental point that undermines the entire allegation: **nowhere in Rules P7, P8, Q7, Q8, or Appendix 7 is there any requirement for "full disclosure of wages" as alleged by the Premier League**.
This represents a critical disconnect between the charges and the actual regulatory framework. The Premier League alleges that Manchester City failed to provide "accurate financial information" regarding manager remuneration, implying that there was a duty to disclose all aspects of Mancini's compensation arrangements. However, when the cited rules are examined in their entirety, no such disclosure requirement exists.
The absence of any wage disclosure mandate in the cited regulations means that the allegation is fundamentally unsupported by the Premier League's own rules. This is not a matter of interpretation or legal nuance—it is a straightforward reading of the regulatory text that reveals the charges to be based on requirements that simply do not exist.
## Analysis of Premier League Rule P7
Premier League Rule P7, as detailed in the official handbook, states:
> "The terms of a Manager's employment must be evidenced in a written contract, a copy of which must be submitted to the Board within seven days of its coming into full force and effect." [4]
This rule is straightforward in its requirements: it mandates that manager employment contracts must be in writing and submitted to the Premier League Board within seven days. **Critically, Rule P7 contains no requirement for disclosure of wages, compensation details, or any financial information whatsoever**. The rule is purely procedural, requiring only that a written contract exists and is submitted—it does not specify what information that contract must contain or what additional disclosures might be required.
Crucially, Rule P7 addresses only the formal employment relationship between the club and the manager—it does not extend to regulating separate contractual arrangements that a manager might have with third parties for purposes unrelated to their football management duties. The Mancini-Al Jazira arrangement was not an employment contract between Manchester City and Mancini. It was a separate consultancy agreement between Mancini and Al Jazira FC, designed to address legitimate tax planning objectives. Rule P7 simply does not apply to such arrangements because they fall outside the scope of the manager's employment relationship with the Premier League club.
The Premier League's attempt to apply Rule P7 to the Al Jazira arrangement represents a fundamental misunderstanding of the rule's scope and purpose. The rule is designed to ensure transparency in the direct employment relationship between clubs and managers, not to regulate every possible contractual relationship that a manager might have with entities within a broader ownership structure.
## Analysis of Premier League Rule P8
Premier League Rule P8 provides more detailed requirements for the contents of manager employment contracts:
> "Contracts of employment between a Club and a Manager shall:
> P.8.1. include the standard clauses set out in Appendix 7; and
> P.8.2. clearly set out the circumstances in which the contract of employment may be determined by either party." [4]
Rule P8 is specifically concerned with the contents of employment contracts between clubs and managers. **Importantly, while P8 specifies that contracts must include standard clauses and termination provisions, it contains no requirement for wage disclosure or financial reporting**. The rule addresses contract structure and standard terms, not compensation transparency.
Like Rule P7, P8 addresses only the direct employment relationship and does not extend to separate contractual arrangements for non-employment purposes. The requirement to include "standard clauses set out in Appendix 7" is particularly significant because these clauses, when examined in detail, reveal the limited scope of the Premier League's regulatory authority over manager contracts. The standard clauses are designed to ensure that managers comply with football-related obligations and avoid conflicts of interest in their capacity as football managers—they do not purport to regulate legitimate business activities outside the football context, nor do they require disclosure of non-employment compensation.
It is noteworthy that in later years, Rules P7 and P8 were renumbered as Q7 and Q8 respectively, but their substantive content remained identical [3]. This consistency demonstrates that the Premier League's regulatory approach to manager contracts has remained stable over time and has never extended to the type of arrangement that existed between Mancini and Al Jazira FC.
## Detailed Analysis of Appendix 7: Standard Clauses
Appendix 7 of the Premier League Rules sets out the "Standard Clauses for inclusion in Managers' Contracts of Employment" and provides the most detailed insight into what the Premier League actually requires of manager contracts [4]. The three standard clauses are:
### Clause 1: Compliance with Rules and Regulations
> "The Manager shall observe and comply with the rules and regulations for the time being in force of any organisation or body the rules and regulations of which the Club is bound to observe including those of The Football Association and the League and in particular he shall at all times act in accordance with the League's Code of Conduct for Managers."
This clause requires managers to comply with football-related rules and regulations in their capacity as football managers. It does not prohibit managers from entering into separate contractual arrangements for legitimate business purposes unrelated to their football management duties. The Al Jazira arrangement was a tax planning mechanism, not a football-related activity that would fall under this compliance requirement.
### Clause 2: Commercial Conflicts
> "The Manager shall comply with all reasonable instructions and requests
> (a) given to Club Managers by the League or
> (b) given to the Manager by the Club
> which arise in the first case out of any commercial contract entered into by the League for the benefit of its members or in the second case out of any such contract entered into by the Club for its own benefit and the Manager shall not himself enter into any such contract which conflicts or competes or is reasonably likely to conflict or compete with those entered into by the League or by the Club as aforesaid."
This clause addresses potential commercial conflicts between a manager's personal commercial activities and those of the League or Club. However, the Al Jazira arrangement was not a commercial contract that competed with League or Club activities—it was a tax planning arrangement designed to address Mancini's personal tax obligations across multiple jurisdictions.
The clause specifically refers to contracts that "conflict or compete" with League or Club commercial activities. A tax planning arrangement that helps a manager comply with international tax obligations cannot reasonably be characterised as conflicting with or competing with football-related commercial activities.
### Clause 3: Dispute Resolution
> "Any dispute or difference arising between the parties hereto as to the construction of this Agreement or the rights duties or obligations of either party hereunder or any matter arising out of or concerning the same or the Manager's employment hereunder shall be referred to the Managers' Arbitration Tribunal in accordance with the Rules of the League for the time being in force."
This clause establishes dispute resolution procedures for employment-related matters. It has no bearing on the Al Jazira arrangement, which was not part of Mancini's employment agreement with Manchester City.
## The Complete Absence of Wage Disclosure Requirements
Having examined Rules P7, P8, and Appendix 7 in their entirety, a critical fact emerges: **none of these regulations contain any requirement for clubs to disclose manager wages, compensation details, or financial arrangements beyond the basic employment contract**. This represents a fundamental flaw in the Premier League's case.
The rules cited by the Premier League in support of their allegations are:
- **Rule P7**: Requires written contracts to be submitted—contains no wage disclosure requirement
- **Rule P8**: Specifies contract contents and standard clauses—contains no wage disclosure requirement
- **Appendix 7**: Sets out standard clauses for compliance, commercial conflicts, and disputes—contains no wage disclosure requirement
- **Rules Q7 and Q8**: Identical to P7 and P8 respectively—contain no wage disclosure requirement
The Premier League's allegation that Manchester City failed to provide "accurate financial information" regarding manager remuneration assumes the existence of a disclosure obligation that simply does not exist in the cited regulations. This is not a matter of legal interpretation—it is a straightforward factual observation that the rules do not contain the requirements alleged.
## The Fundamental Scope Problem
The critical flaw in the Premier League's case becomes clear when the actual text of Rules P7, P8, and Appendix 7 is examined in detail. These rules are specifically designed to regulate the employment relationship between Premier League clubs and their managers. They do not extend to regulating separate contractual arrangements that managers might have with third parties for purposes unrelated to their football management duties.
The Al Jazira arrangement was fundamentally different from the type of relationship governed by these rules. It was:
1. **Not an employment contract** - It was a consultancy agreement for tax planning purposes
2. **Not with Manchester City** - It was between Mancini and Al Jazira FC
3. **Not football-related** - It was designed to address international tax obligations
4. **Not competitive or conflicting** - It did not compete with any League or Club commercial activities
The Premier League's attempt to apply employment contract regulations to a separate tax planning arrangement represents a fundamental category error. It is analogous to arguing that employment law should govern a manager's personal mortgage arrangements simply because both involve contractual obligations.
## The Tax Planning Context
The evidence clearly demonstrates that the Al Jazira arrangement was a legitimate tax planning strategy designed to prevent double taxation—a common issue for individuals working across multiple jurisdictions with different residency requirements [1]. The arrangement was designed to ensure Mancini did not face the prospect of paying tax in both the United Kingdom and Italy, a situation that could have resulted in him losing as much as 97% of his earnings.
This type of tax planning is not only legal but commonplace among high-earning individuals who work across international boundaries. The fact that similar arrangements have been employed by numerous other footballers and managers, including Harry Kane, Robbie Keane, Gareth Bale, Rio Ferdinand, Harry Redknapp, Steven Gerrard, Wayne Rooney, and David Beckham, demonstrates that such strategies are standard practice within the football industry [1].
The Premier League rules cited in the charges simply do not address tax planning arrangements. Rules P7 and P8 are concerned with employment contracts and their contents, not with how managers structure their personal tax affairs across multiple jurisdictions.
## The Timing Factor and PSR Irrelevance
A crucial element that further undermines the Premier League's case is the timing of the arrangement. The evidence clearly indicates that the entire scheme was completed before the start of the 2013-2014 season, predating the implementation of Profit and Sustainability Rules (PSR) [1]. This temporal disconnect raises serious questions about the relevance of these allegations to any current regulatory framework.
The fact that the arrangement concluded before PSR came into effect means it cannot have any bearing on the club's compliance with financial regulations that did not exist at the time. Even if the Premier League's interpretation of Rules P7 and P8 were correct (which it is not), the timing issue alone should be sufficient to dismiss this aspect of the charges.
## Evidentiary Concerns and Document Manipulation
The reliability of the evidence supporting these allegations is fundamentally compromised by documented manipulation and selective editing. Manchester City's revelation that at least one crucial email was actually a combination of two separate messages spliced together represents a devastating blow to the credibility of the evidence [1].
This discovery is not merely a technical issue but reveals a systematic willingness to manipulate evidence to support predetermined conclusions. The splicing of emails fundamentally alters their meaning and context, transforming legitimate business correspondence into apparent evidence of wrongdoing.
The manipulation of evidence by Rui Pinto, including the splicing of emails, indicates a willingness to distort the narrative to support predetermined conclusions [1]. When combined with the extensive redaction of names and email addresses in the leaked documents, this creates a situation where the reliability of the entire document collection becomes questionable.
## The Red Herring Characterisation
The video analysis characterises the Mancini allegations as a "red herring," arguing that the rules cited are being twisted and do not actually forbid extra payments [2]. This assessment is entirely accurate when the actual text of Rules P7, P8, and Appendix 7 is examined in detail.
The Premier League's rules are designed to ensure fair competition and financial transparency within the context of football operations. They are not intended to regulate legitimate business arrangements between individuals and entities for purposes unrelated to competitive advantage or financial circumvention.
The Mancini arrangement, being a tax planning strategy rather than an attempt to provide additional football-related compensation, falls entirely outside the scope of regulations designed to prevent financial manipulation in football contexts. The Premier League's attempt to characterise this as a breach of reporting requirements represents a fundamental misunderstanding of both the nature of the arrangement and the scope of their own rules.
## Comparative Analysis and Industry Practice
The widespread use of similar tax planning arrangements throughout the football industry demonstrates that the Premier League's interpretation of its rules in this case is both novel and problematic. If such arrangements were indeed prohibited by Rules P7, P8, and Appendix 7, one would expect to see consistent enforcement across the league, yet no such pattern exists.
The fact that other high-profile figures in football have employed similar strategies without facing regulatory action indicates either selective enforcement or a misinterpretation of the rules in Manchester City's case. This inconsistency undermines the credibility of the charges and suggests that the Premier League is applying standards retroactively or selectively.
## Legal Standing and Jurisdictional Overreach
The Premier League's attempt to regulate tax planning arrangements raises fundamental questions about the scope of its jurisdiction and authority. Football governing bodies are granted specific powers to regulate sporting and commercial activities related to football competition. Extending this authority to encompass personal tax planning strategies of individuals represents a significant overreach.
Rules P7, P8, and Appendix 7 are specifically limited to employment relationships and football-related activities. They do not grant the Premier League authority to regulate how managers structure their personal tax affairs, particularly when such arrangements involve entities outside the direct club-manager employment relationship.
The arrangement between Mancini and Al Jazira FC was a private contractual matter designed to address legitimate tax obligations. The Premier League lacks both the expertise and authority to adjudicate on the appropriateness of international tax planning strategies, particularly when such arrangements do not impact competitive balance or financial fair play.
## The Premier League Statement Context
The Premier League's official statement of 6 February 2023 lists the specific rules allegedly breached, but when these rules are examined in detail, it becomes clear that they do not support the allegations regarding the Mancini arrangement [3]. The statement's reference to "accurate financial information" and "manager remuneration" appears to assume that the Al Jazira arrangement should have been reported as part of Mancini's employment with Manchester City, but this assumption is not supported by the actual text of the rules.
The rules cited in the statement—P7, P8, and their later equivalents Q7 and Q8—are specifically concerned with employment contracts between clubs and managers. They do not require disclosure of separate contractual arrangements for non-employment purposes, nor do they prohibit managers from entering into legitimate business relationships with third parties.
## The False Premise of the Charge
The fundamental flaw in the Premier League's case is that it rests on a false premise: that the Al Jazira arrangement was part of Mancini's remuneration from Manchester City and should therefore have been disclosed under Rules P7 and P8. However, the evidence clearly demonstrates that this arrangement was a separate tax planning mechanism, not additional compensation for football management services.
The Premier League's rules do not require clubs to report every contractual relationship that their managers might have with entities within a broader ownership structure, particularly when such relationships serve legitimate non-football purposes. To interpret the rules in this way would create an impossible reporting burden and extend the Premier League's regulatory authority far beyond its intended scope.
## Conclusion
The allegations concerning Roberto Mancini's remuneration arrangements represent a fundamental misapplication of Premier League Rules P7, P8, and Appendix 7. **Most critically, when the actual text of these rules is examined in detail, none of them contain any requirement for "full disclosure of wages" or comprehensive reporting of manager compensation arrangements as alleged by the Premier League**.
This absence of any wage disclosure mandate in the cited regulations represents a fatal flaw in the Premier League's case. The charges are based on an alleged failure to comply with disclosure requirements that simply do not exist in the rules cited to support them. This is not a matter of legal interpretation or regulatory nuance—it is a straightforward factual observation that undermines the entire allegation.
When the actual text of these rules is examined in detail, it becomes clear that they are specifically designed to regulate employment relationships between clubs and managers, not separate contractual arrangements for tax planning purposes. The Premier League's attempt to apply employment contract regulations to a legitimate tax planning arrangement represents a category error of the most basic kind. Rules P7 and P8 require written employment contracts and specify their contents—they do not prohibit or regulate separate business arrangements between managers and third parties for purposes unrelated to football management.
The standard clauses set out in Appendix 7 are designed to prevent conflicts of interest in football-related activities and ensure compliance with football regulations. They do not extend to regulating how managers structure their personal tax affairs across multiple jurisdictions, nor should they.
The evidence clearly demonstrates that the Al Jazira arrangement was a legitimate tax planning strategy designed to prevent double taxation, not an attempt to circumvent Premier League regulations or provide undisclosed additional compensation. The timing of the arrangement, predating relevant financial rules, further undermines any claim of regulatory breach.
The Premier League's pursuit of these charges appears to represent an overreach of authority and a fundamental misinterpretation of both the evidence and their own regulations. The characterisation of this arrangement as a failure to accurately report manager wages is not supported by the actual text of Rules P7, P8, and Appendix 7, and represents a concerning expansion of sporting authority into areas where it has neither expertise nor jurisdiction.
This aspect of the case should be dismissed on multiple grounds: the rules cited do not apply to the arrangement in question, the arrangement was legitimate and legal, the timing predates relevant regulations, and the evidence has been demonstrably manipulated. The Premier League's attempt to transform a legal tax planning strategy into a regulatory breach represents a fundamental misunderstanding of both the scope of their own rules and the nature of the arrangement they seek to regulate.
The detailed examination of Rules P7, P8, and Appendix 7 reveals that these regulations are carefully crafted to address specific aspects of the employment relationship between clubs and managers. They do not provide a general mandate to regulate all aspects of managers' business affairs, nor should they be interpreted in such an expansive manner. The Premier League's case in this area appears to be built on a misreading of their own rules and should not be permitted to proceed.
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## References
[1] ManCityStuff. "Allegation 2 – Mancini and Toure." Available at: https://mancitystuff.co.uk/allegation-2-mancini-and-toure/
[2] Ted Fred Franky. "Man City PSR The Facts." YouTube video. Available at: https://youtu.be/UWeD_KwgWSg?si=bAJ_8qSdsU2kyls8
[3] Premier League. "Premier League statement." 6 February 2023. Available at: https://www.premierleague.com/news/3072490
[4] Premier League. "Premier League Handbook 2023/24." Rules P7, P8, and Appendix 7.
