The fact that PSG seems to have paid, directly or indirectly, an amount of EUR 222 million to Barcelona is likely to result in (inter)national taxation issues. The payment or reimbursement of the release fee owed by Neymar to FC Barcelona may qualify as a “benefit in kind” in the hands of Neymar, potentially taxable as additional salary. As a result PSG may end up having to pay a significantly higher (grossed up) amount. To the extent that the payment is to be qualified as a payment made by PSG to secure Neymar’s future services, French social security and tax law will have to be considered. In addition, there is the risk that Neymar’s training clubs will claim solidarity contributions regarding this amount. For the “loan and option to buy” – the construction used for Mbappé’s transfer - it will be interesting to...
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