HM Revenue and Customs reportedly opened an investigation into Manchester City in 2018 to establish whether the Premier League giants had used elaborate arrangements to dodge tax. That investigation took place almost a decade before the club was found guilty of breaching top-flight financial regulations by an independent commission.
Investigation triggered by leaked emails
City were convicted on all but one of the Premier League's charges following a probe spanning nearly 10 years. The Financial Times reports that UK tax authorities launched a civil investigation into the club's financial affairs after a cache of internal emails was leaked by Der Spiegel in 2018.
It was those leaked emails that triggered the Premier League's own investigation, which got under way in December of that year, examining whether the club had manipulated its finances.
Findings of the independent commission
The findings of the independent commission, published last month, concluded that City had artificially inflated their finances by more than £900m between 2009 and 2018 through so-called 'sham' commercial deals. The club continues to strenuously deny those allegations and has lodged an appeal against the guilty verdict.
The recently published report reveals that the club concealed funding from owner Sheikh Mansour bin Zayed al-Nahyan by disguising it as commercial revenue. The verdict has sent shockwaves throughout European football, with the consequences of the investigation showing no signs of abating.
HMRC inquiry never formally concluded
The Financial Times report further claims that HMRC's earlier inquiry was never formally concluded, having been conducted under a so-called Code of Practise 8 investigation. It's a civil inquiry deployed by the authority when they suspect an individual or organisation has employed complex structures to circumvent tax obligations, though COP8 investigations do not involve allegations of deliberate fraud.
It's understood City enlisted external lawyers to provide guidance on the probe, with the club maintaining to HMRC that there was nothing improper about its commercial arrangements. Consequently, HMRC has not pursued any action.
Both Man City and HMRC declined to comment. The 2018 investigation has emerged just a week after Chair of the Treasury select committee, Dame Meg Hillier, wrote to HMRC to seek information about the Premier League's investigation into the club.
Appeal lodged against verdict
Hillier requested reassurance from permanent secretary of the tax authority, John-Paul Marks, that he understood "the importance" of the case. Manchester City formally submitted an appeal against the damning verdict last week, having had until Friday, 2 October to do so.
Their statement read: "Manchester City Football Club can confirm that, at 7pm on Thursday 1st October 2026, the club lodged its comprehensive appeal against the opinion of the Premier League commission, in relation to the Premier League disciplinary matter."
"The club's firm position is that, on multiple grounds, the opinion contains clear material errors, of law, principle and fact, and is unsafe. The club is innocent of the accusations made by the Premier League and a comprehensive body of irrefutable evidence exists in support of all of its positions relating to this case."
"We will continue to respect due process and are necessarily restricted in what we can say further until all proceedings are complete."