Will there be VAT on Juventus' sale of Paul Pogba for €100m?

In August 2016 Juventus will release Paul Pogba from his contract to play for Manchester United.  In return for Juventus' withdrawal of their right to hold Mr Pogba on their roster, Juventus will accept a one-time transfer fee of €100m from Manchester United - a new world record.  How VAT will ultimately be charged on this transaction is only known to the VAT departments of each club - but those of us on the outside can still make a reasonable guess based on the well known VAT laws and principles.

Brisal v Fazenda Pública [2016] EUECJ C-18/15

Brisal - Auto Estradas do Litoral SA & KBC Finance Ireland v Fazenda Pública - In the European Court of Justice (ECJ)

Brisal, a Portuguese resident company manages a large highway in Portugal and earns revenue from the associated tolls.  In 2004 the company entered into a financing arrangement with a large number of financial institutions, in particular the co-litigant in this case KBC Finance Ireland (an Irish resident company).  The financing amounted to €262m, so was presumably related to the construction of the highway itself.

Greene King Plc v HMRC EWCA [2016] Civ 782

The Greene King Group hold a broad investment portfolio ranging from property leasing to brewing.  This case concerns the accounting treatment of the group's loan arrangements.  In particular, where the rights to 'future interest payments' of a loan were sold to a third party.  The companies involved were:

Stolkin v HMRC [2016] EWCA Civ 447

This case concerns the application of mathematics to capital gains tax computation.

Although the two tax concessions have since changed form, the principle concern of this case - being in what order a taxpayer should apply two separate but applicable tax concessions is an important issue.