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CAS 2012A3025 Club Galatasaray AS v Hugo Issa (CAS)

Why it matters

This case clarifies that when a player is on loan, the original club is not obliged to pay the agent's commission if the commission was to be deducted from the player's salary, because no salary is paid during the loan. It reinforces the principle that loan agreements suspend the employment contract's salary obligations, and that agent fees are typically paid from the player's earnings.

Summary

The case concerns a dispute between Turkish club Galatasaray and players' agent Hugo Issa over commission payments for player M. Galatasaray signed M in 2006 and agreed to pay Issa a commission of 10% of M's salary, deducted at source. M was loaned to three different clubs during the 2008-2011 seasons. Issa claimed commission for the 2010/11 season, and FIFA's Players' Status Committee awarded him USD 75,000. Galatasaray appealed to CAS, arguing that because M was on loan and not receiving salary from them, there was no salary from which to deduct the commission. The CAS Sole Arbitrator found that the Payment Contract was a mechanism for Galatasaray to pay Issa on behalf of M by deducting from M's salary. During loans, M's salary from Galatasaray was suspended, so no deduction could be made. The arbitrator also noted that Galatasaray had failed to provide the third loan agreement to FIFA, but CAS could consider it on de novo review. The appeal was upheld, and the FIFA decision set aside, meaning Galatasaray owed nothing.

The detail

Parties: CAS 2012A3025 Club Galatasaray AS v Hugo Issa

Outcome: The appeal was upheld; the FIFA decision was set aside; no sum is payable by Galatasaray to Mr Issa.

Applicable law: FIFA Regulations on the Status and Transfer of Players, FIFA Players' Agents Regulations, Swiss law

Issues in play: Whether a club must pay an agent's commission when the player is on loan and not receiving salary from the club. The Payment Contract was interpreted as a deduction mechanism, not an unconditional obligation.

Read the full decision at Court of Arbitration for Sport (football, via FIFA) ↗

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