Soccer Player and Relocation Bonus: A Case Study
An Italian soccer player who plays as a forward for a club in the south of France had filed claims seeking to benefit from the flat-rate exemption for the relocation bonus.
administration had rejected his appeal, and the case had been taken all the way to the Administrative Court of Appeals.
The tax authority will then verify whether the conditions for the exemption were met, and in particular the condition that the footballer's compensation was not lower than thatfor"similar positions within the company."
The latter had attempted to present this evidence to the Court by submitting:
a statement from the club indicating that "the gross annual compensation that could be paid to an employee for duties similar (as a professional player) to those currently performed by [the soccer player] could amount to 2,000,000 euros";
excerpts from the newspaper L'Equipe citing estimates of the club's players' salaries.
The Court will, however, hold that the General Court was entitled to conclude that this evidence was insufficient to prove that the player’s remuneration was not lower than that for comparable positions.
She believes that the statement was written in the conditional tense and that the excerpts from *L'Equipe* referred only to an estimate of the compensation.
Before the Administrative Court of Appeal, the soccer player had nevertheless submitted anonymized extracts from the social security records of three players from the club, along with a statement from the club confirming that they were forwards. These documents showed that the players’ salaries were lower than the soccer player’s.
The Court then rejected theadministration arguments, which included the claim that it was not possible to identify the players and that the club had seven forwards during the seasons in question.
The judges will base their decision in part on information published by the newspaper L'Equipe, which reported that the club had only three starting forwards.
The Court therefore finds that the taxpayer was indeed entitled to a 30% reduction in the tax base under the flat-rate exemption for the expatriation allowance.
CAA Marseille, Dec. 18, 2025, No. 24MA02687
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