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Judicial setback for Atlético de Madrid: Hacienda wins the battle for UEFA fines and gifts to the squad
The Court confirms a fine from the Treasury to Atlético for deducting UEFA sanctions and gifts to the team
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The National Court has confirmed a sanction from the Treasury against Atlético de Madrid for irregular deductions in corporate tax for the 2008-2009 and 2010-2011 fiscal years. The court rejects the rojiblanco club's appeal regarding expenses linked to UEFA fines, gifts to the squad, and provisions for insolvency.
Hacienda wins against Atlético: the Court confirms a fine to the club for deducting UEFA sanctions and gifts to players
The case affects several expenses that Atlético included to reduce its tax base, but which the Tax Agency considered improper. Among them are fines imposed by UEFA, gifts from the club to members of the technical staff, players, employees and suppliers, and provisions for insolvency. The National High Court has dismissed the appeal filed by the entity and has ordered it to pay costs.
Treasury questioned UEFA fines, gifts to the squad, and provisions
The origin of the case lies in a tax inspection on corporate tax of Atlético de Madrid in the fiscal years 2008-2009 and 2010-2011. The Tax Agency understood that the club had incorporated non-deductible expenses to reduce its tax burden.
The most striking part of the file affects UEFA sanctions. The criterion confirmed by the court is that this type of fine cannot be used as a tax-deductible expense. The National Court also upholds the rejection of deductions for gifts to the technical team, players, employees, and suppliers, considering that they were not sufficiently justified as attentions to clients or suppliers.
The ruling holds that the questioned expenses were evidenced in the minutes and that the non-deductibility of administrative sanctions was clear. In the case of gifts and public relations expenses, the problem for the club was the lack of sufficient documentation to demonstrate that these disbursements had a tax fit.
Atlético appealed, but the Court rejects its arguments
Atlético de Madrid requested the annulment of the resolution of the Central Economic-Administrative Court and the sanctioning agreement of the Treasury. The club alleged procedural defects and maintained that the culpability necessary to impose the sanction had not been proven.
The National Court, however, does not accept that thesis. The magistrates consider that there was no defenselessness and that the rojiblanca entity had a reinforced duty of tax knowledge. The sentence underlines that Atlético is a company to which greater fiscal diligence can be demanded than from an ordinary citizen.
That point is important because the court does not treat the case as a simple administrative error. For the Court, the club had sufficient capacity to know that certain expenses, such as administrative fines or sporting sanctions, could not be fiscally deducted.
The sanction came to be provisioned at 3.8 million
The economic impact of the case has been changing over the years. Atlético had provisioned 3.8 million euros for this cause, although that amount was reduced to 228,000 euros in the club's latest accounts, dated June 30, 2025, after some appeals were upheld by the TEAC.
More relevant is the fiscal dimension of the affected negative tax bases. According to the published information, the non-regularized negative bases linked to this cause amount to 11 million euros between the two fiscal years. These bases allow a company to offset losses from previous years to pay less corporate tax when it returns to profitability.
What the ruling means for the Rojiblanco club
The ruling represents a victory for Hacienda against Atlético in a very specific dispute: which expenses a professional football club can deduct in corporate tax and which are excluded.
The key to the failure is clear: a UEFA fine cannot be treated as an ordinary deductible expense. And gifts or presents to staff, employees, or suppliers need solid documentary justification to be considered a tax expense.
For Atlético, the setback is twofold. On the one hand, it loses the appeal against the sanction. On the other hand, the Court orders it to pay the costs of the proceedings, understanding that its appeal should not have succeeded.