HMRC confirmed in a statement that it is looking into a “number of active cases investigating this,” but declined to go into further detail.

“The purpose of the scheme is to avoid employment taxes and VAT on the large commissions paid to football agents,” said the report published Thursday. “In reality, these agents act for players.”

Tax Policy Associates report focused on so-called dual-representation, where the football agents who represent players during contract and transfer negotiations are paid for acting for both the club and the player.

This avoids employment taxes and VAT when the club pays half of the agent’s fees, as is the current standard practice, even though they’re employed and work on behalf of the player. If the player paid their agent’s fee in full, they would need to pay significant taxes to the HMRC.

“We carefully scrutinize arrangements between clubs and employees, and we work closely with the football industry to educate and deal with tax risk head on,” an HMRC spokesperson said in an emailed comment. “Since 2015, from across all tax areas in the football industry, we’ve recovered £573 million that would otherwise have gone unpaid.”

A spokesperson for the Premier League said it is in regular talks with the HMRC about agent fees, and that clubs are “fully aware” of the latest tax rules relating to agent fees.