Asser International Sports Law Blog

Our International Sports Law Diary
The Asser International Sports Law Centre is part of the T.M.C. Asser Instituut

Book Review: Questioning the (in)dependence of the Court of Arbitration for Sport

Book Review: Vaitiekunas A (2014) The Court of Arbitration for Sport : Law-Making and the Question of Independence, Stämpfli Verlag, Berne, CHF 89,00

The book under review is the published version of a PhD thesis defended in 2013 by Andrew Vaitiekunas at Melbourne Law School. A PhD is often taking stock of legal developments rather than anticipating or triggering them. This was definitely not the case of this book. Its core subject of interest is the study of the independence of the Court of Arbitration for Sport (CAS) – an issue that has risen to prominence with the recent Pechstein ruling of January 2015 of the Oberlandesgericht München. It is difficult to be timelier indeed. More...



The Court of Arbitration for Sport after Pechstein: Reform or Revolution?

The Pechstein ruling of the Oberlandesgericht (OLG) München rocked the sports arbitration world earlier this year (see our initial commentary of the decision here and a longer version here). The decision has been appealed to the German Bundesgerichtshof (BGH), the highest German civil court, and the final word on the matter is not expected before 2016. In any event, the case has the merit of putting a long-overdue reform of the Court of Arbitration for Sport (CAS) back on the agenda. The last notable reform of the structure and functioning of the CAS dates back to 1994, and was already triggered by a court ruling, namely the famous Gundel case of the Swiss Federal Tribunal (SFT). Since then, the role of the CAS has shifted and its practical significance has radically changed (the growth of CAS’s caseload has been exponential). It has become the most visible arbitration court in Switzerland in terms of the number of awards appealed to the SFT, but more importantly it deals with all the high-profile disputes that arise in global sport: think, for instance, of Pistorius, the recent Dutee Chand decision or the upcoming FIFA elections.More...

Sports governance 20 years after Bosman: Back to the future… or not? By Borja García

Editor's note:

Dr Borja García joined the School of Sport, Health and Exercise Sciences at Loughbourough University in January 2009 as a Lecturer in Sport Management and Policy. He holds a PhD in Politics, International Relations and European Studies from Loughborough University (United Kingdom), where he completed his thesis titled ‘The European Union and the Governance of Football: A game of levels and agendas’.

 

In this leafy and relatively mild autumn, we are celebrating two important anniversaries. Recently, we just passed ‘Back to the Future day’, marking the arrival of Marty McFly to 2015. In a few weeks, we will be commemorating the 20th anniversary of the Bosman ruling. Difficult to decide which one of the two is more important. As we move well into the 21st century’s second decade, these two dates should mark a moment to consider innovation. They are perhaps occasions to take stock and reflect how much sport has evolved to reach this new future… or not. More...


The 2006 World Cup Tax Evasion Affair in Germany: A short guide. By Gesa Kuebek

Editor's note:

Gesa Kuebek holds an LLM and graduated from the University of Bologna, Gent and Hamburg as part of the Erasmus Mundus Master Programme in Law and Economics and now work as an intern for the Asser Instituut.


On Monday, 9 November, the German Football Association (DFB) announced in a Press Release the resignation of its head, Wolfgang Niersbach, over the 2006 World Cup Affair. In his statement, Niersbach argued that he had “no knowledge whatsoever” about any “payments flows” and is now being confronted with proceedings in which he was “never involved”. However, he is now forced to draw the “political consequences” from the situation. His resignation occurred against the backdrop of last week’s raid of the DFB’s Frankfurt headquarters and the private homes Niersbach, his predecessor Theo Zwanziger and long-standing DFB general secretary Horst R. Schmidt. The public prosecutor’s office investigates a particularly severe act of tax evasion linked to awarding the 2006 World Cup. The 2006 German “summer fairy-tale” came under pressure in mid-October 2015, after the German magazine “Der Spiegel” shocked Fußballdeutschland by claiming that it had seen concrete evidence proving that a €6.7 million loan, designated by the FIFA for a “cultural programme”, ended up on the account of Adidas CEO Robert-Louis Dreyfuß. The magazine further argued that the money was in fact a secret loan that was paid back to Dreyfuß. Allegedly, the loan was kept off the books intentionally in order to be used as bribes to win the 2006 World Cup bid. The public prosecutor now suspects the DFB of failing to register the payment in tax returns. German FA officials admit that the DFB made a “mistake” but deny all allegations of vote buying. However, the current investigations show that the issues at stakes remain far from clear, leaving many questions regarding the awarding of the 2006 World Cup unanswered.

The present blog post aims to shed a light on the matter by synthetizing what we do know about the 2006 World Cup Affair and by highlighting the legal grounds on which the German authorities investigate the tax evasion. More...




Blog Symposium: Ensuring proportionate sanctions under the 2015 World Anti-Doping Code. By Mike Morgan

Introduction: The new WADA Code 2015
Day 1: The impact of the revised World Anti-Doping Code on the work of National Anti-Doping Agencies
Day 2: The “Athlete Patient” and the 2015 World Anti-Doping Code: Competing Under Medical Treatment
Day 3: Proof of intent (or lack thereof) under the 2015 World Anti-Doping Code

Editor's note
Mike Morgan is the founding partner of Morgan Sports Law LLP. His practice is focused exclusively on the sports sector. He advises on regulatory and disciplinary issues and has particular experience advising on doping and corruption disputes.

Mike acted on behalf of National Olympic Committees at three of the last four Olympic Games and has represented other sports bodies, clubs and high profile athletes in proceedings before the High Court, the FIFA Dispute Resolution Chamber, the American Arbitration Association and the Court of Arbitration for Sport. More...






Blog Symposium: Proof of intent (or lack thereof) under the 2015 World Anti-Doping Code. By Howard L. Jacobs

Introduction: The new WADA Code 2015
Day 1: The impact of the revised World Anti-Doping Code on the work of National Anti-Doping Agencies
Day 2: The “Athlete Patient” and the 2015 World Anti-Doping Code: Competing Under Medical Treatment
Day 4: Ensuring proportionate sanctions under the 2015 World Anti-Doping Code

Editor's note

Howard Jacobs is solo practitioner in the Los Angeles suburb of Westlake Village, California. Mr. Jacobs has been identified by various national newspapers and publications as one of the leading sports lawyers in the world. His law practice focuses on the representation of athletes in all types of disputes, with a particular focus on the defense of athletes charged with doping offenses.Mr. Jacobs has represented numerous professional athletes, Olympic athletes, world record holders,  and amateur athletes in disputes involving doping, endorsements, unauthorized use of name and likeness, salary issues, team selection issues, and other matters.  He is at the forefront of many cutting edge legal issues that affect athletes, winning cases that have set precedents that have benefited the athlete community. More information is available at www.athleteslawyer.com. More...





Blog Symposium: The “Athlete Patient” and the 2015 World Anti-Doping Code: Competing Under Medical Treatment. By Marjolaine Viret and Emily Wisnosky

Introduction: The new WADA Code 2015
Day 1: The impact of the revised World Anti-Doping Code on the work of National Anti-Doping Agencies
Day 3: Proof of intent (or lack thereof) under the 2015 World Anti-Doping Code
Day 4: Ensuring proportionate sanctions under the 2015 World Anti-Doping Code

Editor's Note
Marjolaine Viret: An attorney-at-law at the Geneva bar, specialising in sports and health law. Her doctoral work in anti-doping was awarded a summa cum laude by the University of Fribourg in early 2015. She gained significant experience in sports arbitration as a senior associate in one of Switzerland’s leading law firms, advising clients, including major sports federations, on all aspects of anti-doping. She also holds positions within committees in sports organisations and has been involved in a variety of roles in the implementation of the 2015 WADC. Her book “Evidence in Anti-Doping at the Intersection of Science & Law” is scheduled for publication in 2015.

Emily Wisnosky: An attorney-at-law admitted to the California bar, she currently participates in the WADC 2015 Commentary research project as a doctoral researcher. She also holds an LLM from the University of Geneva in International Dispute Settlement, with a focus on sports arbitration. Before studying law, she worked as a civil engineer. More...





Blog Symposium: The impact of the revised World Anti-Doping Code on the work of National Anti-Doping Agencies. By Herman Ram

Introduction: The new WADA Code 2015
Day 2: The “Athlete Patient” and the 2015 World Anti-Doping Code: Competing Under Medical Treatment
Day 3: Proof of intent (or lack thereof) under the 2015 World Anti-Doping Code
Day 4: Ensuring proportionate sanctions under the 2015 World Anti-Doping Code

Editor's note
Herman Ram is the Chief Executive Officer of the Anti-Doping Authority the Netherlands, which is the National Anti-Doping Organization of the country. He has held this position since 2006. After working twelve years as a librarian, Herman Ram started his career in sport management in 1992, when he became Secretary general of the Royal Netherlands Chess Federation. In 1994, he moved on to the same position at the Netherlands Badminton Federation. He was founder and first secretary of the Foundation for the Promotion of Elite Badminton that was instrumental in the advancement of Dutch badminton. In 2000 he was appointed Secretary general of the Netherlands Ski Federation, where he focused, among other things, on the organization of large snowsports events in the Netherlands. Since his appointment as CEO of the Anti-Doping Authority, he has developed a special interest in legal, ethical and managerial aspects of anti-doping policies, on which he has delivered numerous presentations and lectures. On top of that, he acts as Spokesperson for the Doping Authority. Herman Ram holds two Master’s degrees, in Law and in Sport Management. More...




Blog Symposium: The new WADA Code 2015 - Introduction

Day 1: The impact of the revised World Anti-Doping Code on the work of National Anti-Doping Agencies
Day 2: The “Athlete Patient” and the 2015 World Anti-Doping Code: Competing Under Medical Treatment
Day 3: Proof of intent (or lack thereof) under the 2015 World Anti-Doping Code
Day 4: Ensuring proportionate sanctions under the 2015 World Anti-Doping Code

On 1 January, a new version of the World Anti-Doping Code (WADC or Code) entered into force. This blog symposium aims at taking stock of this development and at offering a preliminary analysis of the key legal changes introduced. The present blog will put the WADC into a more general historical and political context. It aims to briefly retrace the emergence of the World Anti-Doping Agency (WADA) and its Code. It will also reconstruct the legislative process that led to the adoption of the WADC 2015 and introduce the various contributions to the blog symposium.More...






To pay or not to pay? That is the question. The case of O’Bannon v. NCAA and the struggle of student athletes in the US. By Zlatka Koleva

Editor's note
Zlatka Koleva is a graduate from the Erasmus University Rotterdam and is currently an Intern at the ASSER International Sports Law Centre.

The decision on appeal in the case of O’Bannon v. NCAA seems, at first sight, to deliver answers right on time regarding the unpaid use of names, images and likenesses (NILs) of amateur college athletes, which has been an ongoing debate in the US after last year’s district court decision that amateur players in the college games deserve to receive compensation for their NILs.[1] The ongoing struggle for compensation in exchange for NILs used in TV broadcasts and video games in the US has reached a turning point and many have waited impatiently for the final say of the Court of Appeal for the 9th circuit. The court’s ruling on appeal for the 9th circuit, however, raises more legitimate concerns for amateur sports in general than it offers consolation to unprofessional college sportsmen. While the appellate court agreed with the district court that NCAA should provide scholarships amounting to the full cost of college attendance to student athletes, the former rejected deferred payment to students of up to 5,000 dollars for NILs rights. The conclusions reached in the case relate to the central antitrust concerns raised by NCAA, namely the preservation of consumer demand for amateur sports and how these interests can be best protected under antitrust law. More...



Asser International Sports Law Blog | The EU State aid and Sport Saga: Hungary’s tax benefit scheme revisited? (Part 1)

Asser International Sports Law Blog

Our International Sports Law Diary
The Asser International Sports Law Centre is part of the T.M.C. Asser Instituut

The EU State aid and Sport Saga: Hungary’s tax benefit scheme revisited? (Part 1)

The tax benefit scheme in the Hungarian sport sector decision of 9 November 2011 marked a turning point as regards the Commission’s decisional practice in the field of State aid and sport. Between this date and early 2014, the Commission reached a total of ten decisions on State aid to sport infrastructure and opened four formal investigations into alleged State aid to professional football clubs like Real Madrid and Valencia CF.[1] As a result of the experience gained from the decision making, it was decided to include a Section on State aid to sport infrastructure in the 2014 General Block Exemption Regulation. Moreover, many people, including myself, held that Commission scrutiny in this sector would serve to achieve better accountability and transparency in sport governance.[2]

Yet, a recent report by Transparency International (TI), published in October 2015, raises questions about the efficiency of State aid enforcement in the sport sector. The report analyzes the results and effects of the Hungarian tax benefit scheme and concludes that:

“(T)he sports financing system suffers from transparency issues and corruption risks. (…) The lack of transparency poses a serious risk of collusion between politics and business which leads to opaque lobbying. This might be a reason for the disproportionateness found in the distribution of the subsidies, which is most apparent in the case of (football) and (the football club) Felcsút.”[3]

In other words, according to TI, selective economic advantages from public resources are being granted to professional football clubs, irrespective of the tax benefit scheme greenlighted by the Commission or, in fact, because of the tax benefit scheme.

One would expect TI’s report to be a wake-up call for the Commission, triggering it, as “Guardian of the Treaties”, to re-investigate Hungary’s tax benefit scheme without delay. Further incentives to scrutinize the matter is provided by the Hungarian MEP Péter Niedermüller, who in November 2015 officially asked the Commission whether it intended to review its earlier decision to authorize the tax benefit scheme. The Commission’s answer, seen here below, indicates that immediate action is not to be expected.


Not satisfied with this answer, Niedermüller replied that even though the Commission had authorized the tax scheme in 2011, it does not absolve it “from the obligation to proceed with the appropriate care thereafter and to monitor whether the system is operating in accordance with the objectives originally set”.

The overall aim of this two-part blog is to analyze the rules and procedures surrounding the monitoring of previously authorized aid schemes in the sports sector by the Commission. It will use the tax benefit scheme in the Hungarian sport sector decision as a starting point, describing the objective and the functioning of the aid scheme, as well as the conditions and obligations for Hungary and the Commission attached to it. In continuation, basing myself on the findings and conclusions drawn in the report, I will try to determine whether the current practice in Hungary deviates from the original objectives and conditions of the aid scheme, and what the consequences of such a deviation could be. Do the State aid rules impose an obligation upon the Commission to act and, if so, in what way? Furthermore, could the Hungarian case make one reconsider the usefulness of State aid rules to achieve better accountability and transparency in sport in general? 


The tax benefit scheme in the Hungarian sport sector decision

A description of the scheme

In April 2011, the Hungarian authorities notified the Commission of their plans to introduce a tax benefit scheme with the aim of developing the country’s sport sector.[4] More specifically, via the scheme, they hoped to “increase the participation of the general public in sport activities, by inter alia, promoting mass sport events, training of the young generations as well ensuring adequate sport infrastructure and equipment for the general public”. Due to the existence of a market failure (i.e. a situation where individual market investors do not invest even though this would be efficient from a wider economic perspective), Hungary saw itself obligated to provide public money to the sport sector in order to achieve the aforementioned objectives.[5]

Under the scheme, which will run until 30 June 2017, corporations (operating in any sector that is subject to corporate tax) can choose to donate money to sport organizations, both amateur and professional. Sport organizations may use these resources to train the young generation, cover personnel expenses and to construct/renovate sport infrastructure. The donations would be deducted from the corporation’s taxable income and from their tax liability.[6] Hungary decided to focus the aid scheme on the five most popular team sports in the country, i.e. football, basketball, ice hockey, water polo and handball. The reasoning behind this choice is that the scheme would not only benefit the sport organizations themselves, but also the sportsmen and sportswomen using the facilities, as well as the general public interested in attending the sporting events.[7] Sport organizations wishing to receive donations have to elaborate a development programme (DP), in which they outline the planned use of the donations. The DPs are evaluated by the respective national sport governing bodies (SGBs), who decide whether the sport organization is eligible for the donations. Once the SGBs approve a DP, the sport organizations may approach corporations willing to donate money to them.[8]

In the specific case of donations used for the construction, renovation or maintenance of sport infrastructures, Hungary notified the Commission that it had introduced a monitoring system that serves to avoid any misuse of the donations or cross-subsidizations of other activities of sport organizations. The so-called Controlling Authority (a public entity falling directly under the Ministry of National Resources) monitors compliance of donators and beneficiaries with the central price benchmarking mechanism regarding rental and operation fees of the infrastructure, introduced to limit the distortion of competition arising from the tax benefit scheme.[9]  


The Commission’s decision

As stated above, the donations should be used to fund the development of sport infrastructure, train the youth teams and cover personnel expenses. The Commission agreed with Hungary that the training of youth teams falls outside the scope of EU State aid rules, in line with the 2001 Commission Decision Subventions publiques aux clubs sportifs professionels. Donations used to cover personnel costs could be falling under the General Block Exemption Regulation[10] or the de minimis aid Regulation.[11] Compliance with the two Regulations is a task for the Hungarian authorities.[12] Consequently, and taking into account that amateur sport clubs are generally not considered to be undertakings within the meaning of Article 107(1) TFEU, the tax benefit scheme in the Hungarian sport sector decision only covers aid for the infrastructures used by the professional sport organizations.

Although the tax benefit scheme fulfilled the criteria of Article 107(1), and thus constituted State aid, the Commission declared the scheme compatible with EU law under Article 107(3)c) TFEU. Importantly, the Commission held that the scheme was introduced in a sufficiently transparent and proportionate manner, i.e. that the measure was well-designed to fulfil the objective of developing the country’s sport sector.[13] Moreover, the Commission acknowledged the special characteristics of sport and held that the objective of the scheme is in line with the overall objectives of sport as stipulated in Article 165 TFEU, namely that the EU “shall contribute to the promotion of European sporting issues”, because the sport sector “has enormous potential for bringing the citizens of Europe together, reaching out to all, regardless of age or social origin”.[14]

It is worth mentioning that the Commission took a very similar approach in its decisions on the other State aid measures granted for sport infrastructure. It considers a sport infrastructure as embodying a typical State responsibility for which the granting of State aid is a well-defined objective of common interest.[15]

Finally, to ensure that the monitoring and transparency obligations are carried out properly, the Commission requires Hungary to submit an annual report to the Commission, containing inter alia, information on the total aid amount allocated on the basis of this scheme, the sport infrastructure projects funded, their aid intensities, their beneficiaries, the parameters applied for benchmarking prices, the rents effectively paid by the professional sport organizations, as well as a description on the benefits provided to the general public and on the multifunctional usage of the infrastructures.[16] There is no requirement to publish this annual report. Therefore, assessing whether the information provided by Hungary to the Commission is in line with the actual practice in the country is currently extremely difficult. 


Transparency International report, “Corruption Risks in Hungarian Sports Financing”

The tax benefit scheme in the Hungarian sport sector decision looked like a blue print for the way in which public authorities could grant State aid to the sport sector: It was aimed at a wide scope of recipients and the general public would benefit as well, transparency was guaranteed, monitoring and compliance mechanisms were introduced and, last but not least, it was notified in advance to the European Commission. 


Lack of transparency

However, TI’s report shows that, four years after the scheme was launched, little remains of all those good intentions. To start with, TI claims that Hungary’s objective was not to increase the participation of the general public in sport activities, but simply to make Hungarian football clubs “excel at the European and international levels”.[17] TI’s primary finding is that there is a flagrant lack of transparency on every level regarding the scheme. Most of the data collected in the report was obtained by TI through freedom of information requests.[18]

The first flaw in the scheme is that under Hungarian national laws and regulations, there is no obligation to disclose the identity of the donating corporations. Consequently, even though the SGBs keep count of which clubs are entitled to receive donations and how much they actually received, many questions remain on how the money is distributed in practice.

TI also questions the integrity of the clubs’ eligibility process. The Hungarian SGBs, who are in charge of selecting the clubs worthy of receiving donations, are to a large extent run by people with close ties to the Hungarian Government.[19] Moreover, for the selection process, the SBGs do not need to provide a reasoning behind the decision to choose or not to choose a club worthy of donations. As TI states, the tax benefit scheme poses a serious threat to transparency and accountability, and can lead to illicit lobbying and backroom deals between politicians, businessmen and clubs. 


Disproportionate distribution of beneficiaries

The advantage of using a general tax scheme as a State aid measure is that it leads to many different beneficiaries and is therefore considered as one of the least distortive type of state intervention.[20] However, the functioning of this particular tax benefit scheme creates the exact opposite result a few clubs are clearly favored. According to the report, the subsidies from the tax scheme totaled €649 million in four years. An amount of €240 million was specifically designated for football clubs, 37% of the total amount. Of all the money donated to football, 28% (or €68 million) went specifically to 13 football clubs, who, perhaps unsurprisingly, all play in Hungary’s highest football league.[21] Of these 13 football clubs, Puskás Akadémia FC received by far the highest amount, no less than €30 million. Puskás Akadémia FC plays in Hungary’s top division, but also functions as the youth team of Videoton FC, one of Hungary’s biggest and most successful clubs. Interestingly enough, Puskás Akadémia FC was founded in 2007 by the current Hungarian Prime Minister Viktor Orban. 


Unnecessary construction of new sport infrastructure?

The Hungarian authorities expressed the need in 2011 for adequate sport infrastructure facilities. Due to a market failure, it was necessary for the State to step in and provide the necessary funds, albeit by means of a tax benefit scheme. The Commission agreed with Hungary that there is a lack of investments in sport infrastructure and that using public money to do so is an objective of common interest.[22] The TI report indicates that especially the Hungarian football stadiums have undergone significant upgrades since 2011, but at the same time questions the necessity to use public funds for these upgrades. Hungarian professional football has not been attracting more people to stadiums since 2011. The country’s highest division averaged only 4,897 spectators per game for the 2014/15 season, 624 less than in the previous year.[23] An example of potential unnecessary construction of sport infrastructure is the “Nagyerdei” stadium, opened in 2014,  in the city of Debrecen. The stadium, that can hold over 20,000 spectators, cost €40 million to construct. However, with a match average of 3,400,[24] one wonders whether the construction of this stadium was an objective of common interest, or whether there was another, hidden, agenda. Referring to the well-reported, including by the European Commission, close relationships between Hungary’s businesses and its political elite, TI points to the realistic possibility that the construction and renovation of (football) stadiums through public procurement procedures, was simply a way to for contractors to “finance the economic orbit of influential politicians in return for all manners of political and financial favours”.[25]  


Interim conclusion

TI’s report clearly shows that there is a huge discrepancy between Hungary’s intention to devise a tax benefit scheme benefitting to the entire sport sector, as notified to the Commission in 2011, and the actual operation of the scheme. The necessity for new and renovated football infrastructure appears superfluous and the tax benefit scheme itself proved to be more beneficial for some clubs, particularly Puskás Akadémia FC. Furthermore, the Commission decision declaring the tax benefit scheme compatible with EU law highlighted the transparency of the scheme and acclaimed its monitoring mechanisms. More than four years on, it can be concluded that the scheme is far from transparent and questions can be raised on the independence and functioning of the monitoring mechanisms. Assuming that the Commission receives annual reports by the Hungarian authorities on the tax benefit scheme, why has it not undertaken any action? Is it simply a matter of unwillingness or could the answer be found in EU State aid law and its procedural rules itself? The next part of this blog will analyze the rules and procedures surrounding the monitoring of previously authorized aid schemes by the Commission, and determine whether Commission action can be expected.



[1] An explanation on why the public financing of sports infrastructure and professional sports clubs only started to attract State aid scrutiny in recent years can be read in: Ben Van Rompuy and Oskar van Maren, “EU Control of State Aid to Professional Sport: Why Now?” Forthcoming in: “The Legacy of Bosman. Revisiting the relationship between EU law and sport”, T.M.C. Asser Press, 2016.

[2] See for example Oskar van Maren, “EU State Aid Law and Professional Football: A threat or a Blessing?”, European State Aid Law Quarterly, Volume 15 1/2016, pages 31-46.

[3] Transparency International, “Corruption Risks in Hungarian Sports Financing”, page 41.

[4] Commission Decision of 9 November 2011, SA.31722 – Hungary - Supporting the Hungarian sport sector via tax benefit scheme, paras 2-3.

[5] Ibid., paras 88-90.

[6] Ibid., paras 15-16.

[7] Ibid., paras 28-34.

[8] Transparency International report of 22 October 2015, “Corruption Risks in Hungarian Sports Financing”, page 31.

[9] Commission Decision SA.31722, paras 37-39.

[10] The GBER applicable at the time the decision was taken was Commission Regulation No800/2008 of 6 August 2008.

[11] Commission Decision SA.31722, para 10.

[12] Ibid., para 64.

[13] Ibid., paras 95-98.

[14] Ibid., paras 86-87.

[15] See for example Commission Decision of 20 March 2013, SA.35135 Multifunktionsarena der Stadt Erfurt, para 14.

[16] Commission Decision SA.31722, para 57.

[17] Transparency International report, page 29.

[18] Ibid., page 31.

[19] Ibid., page 32. TI points out that the chairman of the Hungarian FA is CEO of the country’s biggest commercial bank and close to the Government.

[20] Commission Decision SA.31722, para 20.

[21] The TI report actually mentions the clubs as well as their youth academia. The 13 clubs are: Puskás Akadémia FC (aka Felcsút FC, the youth team of Videoton FC); Ferencváros; Újpest FC; Vasas SC; Szolnoki MÁV FC; Debreceni VSC; Diósgyőri VTK; Zalaegerszegi TE; OVI-FOCI; Illés Sport Alapítvány; Budapest Honvéd FC; Balmazújvárosi FC and; Békéscsaba 1912 Előre.

[22] Commission Decision SA.31722, paras 91-93.

[23] Transparency International report, page 38.

[24] Ibid.

[25] Ibid., page 42.

Comments (1) -

  • Colin MIEGE

    5/18/2016 5:51:33 PM |

    This is a very good and deeply investigating paper.
    Congratulations!

Comments are closed