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Malta Files: PSG’s Edinson Cavani saves on tax for image rights

Star-striker of PSG cashed €1.59 million in 2015 via two Maltese companies, saving €482,442 in taxes. The player said he was ‘in perfect compliance’ with his tax obligations

matthew_vella
Matthew Vella
22 May 2017, 7:10pm
By Yann Philippin, Mediapart

Edinson Cavani, the biggest star of the French football championship, has two Maltese companies that collect his sponsorship income, and on which the star player is saving hundreds of thousands on tax.

According to documents found in the Malta Files, which have been scrutinised by the journalists of the EIC, the Uruguayan striker of Paris-Saint Germain has structures that received €1.59 million in 2015 alone, on which Cavani paid 3% of taxes, only €48,405 euros – ten times less than what he would have paid in France, where the corporate tax is at 33.3%.

Contacted by EIC, Edinson Cavani responded by email saying he was “very shocked” at the questions, saying his income in his Maltese companies is “declared and taxed in France” and that he is “in full compliance with [his] tax obligations”.

“In these circumstances, I will not accept that my situation becomes the object of a publicity damaging my image or my reputation, which, given my celebrity, would cause me very serious prejudice,” he said.

Cavani happens to be subject to a tax audit aimed at all foreign players of the PSG, as French daily newspaper Le Parisien revealed in December, specifically related to the years 2012 to 2014.

When he arrived in Paris in the summer of 2013, Cavani was under contract with Adidas. In November 2014, the player announced that he signed with the American firm Nike. Six months earlier, he had set up in Malta the company Edicavaniofficial Limited, which belongs to a second Maltese structure, Rocha Holdings Limited.

Rocha is 99% owned by Edinson Cavani, with address at 24 rue du Commandant Guilbaud in Paris, the address of PSG stadium Parc des Princes. Rocha Holdings in Malta is administered by tax advisors Fortia.

In 2014, Edicavaniofficial did not get any money, probably because the new contract with Nike had not yet taken effect. In 2015, it received €1.59 million. But it also incurred nothing short of €605,743 in administrative expenses – which raises questions about the nature of these costs for companies that usually do not employ anyone except service providers –  which reduced taxable profit to €988,000.

Under the Maltese tax rules, Edicavaniofficial then paid €338,835 in tax at 35%, and paid its dividends to Rocha Holdings, which was entitled to a total refund of €290,430 –recorded in its accounts as a “current tax asset”.

So Cavani paid only €48,805 of corporate tax, instead of €530,847 had the company been registered in France.

EIC member Mediapart submitted this scheme to two lawyers specialized in the management of image rights of high-level athletes, who considered it problematic. That’s because Article 155-A of the French General Tax Code authorizes a footballer resident in France to collect his sponsorship income through a foreign company, but only if the company has a real activity.

“In this case, the tax authorities may consider that it is a pure interposition of the foreign company, which sole purpose is to avoid direct payment to the player, with significant consequences,” the Mediapart expert said.

If the foreign company is considered as artificial by the tax authorities, the image rights money can be taxed again and penalised.

Cavani declared to EIC that he did nothing to hide, since the company Edicavaniofficial “carries [his name]”.

“The income of these companies is declared and taxed in France, in application of the French tax law,” Edinson Cavani told EIC.

MaltaToday is part of the European Investigations Collaborations that is reporting on The Malta Files, which has been made possible through a grant from journalismfund.eu

matthew_vella
Matthew Vella is executive editor at MaltaToday.