CAS 2024 A 10515
CAS · Football (FIFA / CAS) · Switzerland · 2 Apr 2025
Why it matters
This case clarifies the interpretation of 'net' salary clauses in football contracts, particularly in jurisdictions where tax authorities hold the player primarily liable. It confirms that a 'net' clause obliges the club to reimburse the player for any taxes paid on the salary, and that failure to do so can constitute an overdue payable under FIFA RSTP Article 12bis. The decision also reinforces the CAS standard of review for sanctions imposed by FIFA bodies.
Summary
Rizespor AS, a Turkish football club, signed a contract with Brazilian player Ronaldo César Mendes de Medeiros for the 2021-2023 seasons, stipulating that all amounts were 'net' (i.e., the club would bear any taxes). After the club was relegated, it failed to pay the player's salaries and the player received tax notices from Turkish authorities for income tax on his earnings. The player argued that the 'net' clause required the club to pay or reimburse the taxes. The club claimed that under Turkish law, income tax is the player's personal obligation. The FIFA Dispute Resolution Chamber (DRC) ordered the club to pay EUR 140,000 in outstanding salaries and bonuses, plus interest, and imposed a warning for overdue payables. The club appealed to CAS. The CAS panel partially upheld the appeal, reducing the amount to EUR 133,000 (deducting a fine for late arrival to training) and adjusting interest. The panel held that the 'net' clause obliged the club to reimburse the player for taxes paid, but the player had not proven the exact amount of taxes attributable to the club's payments. The warning was upheld as proportionate. The case is significant for its interpretation of 'net' salary clauses and the allocation of tax burdens in international football contracts.
The detail
Parties: Rizespor AS v. Ronaldo Cesar Mendes de Medeiros & FIFA
Case number: CAS 2024 A 10515
Outcome: The appeal is partially upheld. The FIFA DRC decision is partially confirmed, but the amount of outstanding remuneration is reduced to EUR 133,000 net (instead of EUR 140,000) with adjusted interest. The Club is warned for overdue payables. The Club must pay CHF 3,000 towards the Player's legal fees.
Quantum: EUR 133,000 net plus interest
Applicable law: FIFA Regulations on the Status and Transfer of Players (RSTP), particularly Articles 12bis and 14bis; Turkish tax law; CAS Code of Sports-related Arbitration
Issues in play: The case involved a conflict between the contractual obligation to pay 'net' salaries (meaning the Club bears all taxes) and Turkish tax law, which imposes income tax on the player individually. The key issue was whether the Club's failure to pay the player's income tax constituted a breach of the 'net' salary clause.
Read the full decision at Court of Arbitration for Sport (football, via FIFA) ↗
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