The case revolves around a dispute between Parma FC S.p.A. and Manchester United F.C. concerning training compensation for a young player who moved from Parma to Manchester United. The player was registered as an amateur with Parma from January 2000 to June 2004, between the ages of 12 and 17, before signing his first professional contract with Manchester United in November 2004. Parma claimed it was entitled to higher training compensation than the indicative amounts set by FIFA, arguing these were disproportionate to its actual training expenses. Manchester United, however, insisted on adhering to FIFA Regulations and Circular Letters, initially offering EUR 200,000, later increasing to EUR 280,000, which Parma rejected.
The dispute was first brought before FIFA's Dispute Resolution Chamber (DRC), which ruled in June 2005 that Manchester United should pay EUR 205,000, based on FIFA Regulations and Circular 826, as Parma failed to prove the indicative amounts were disproportionate. Parma appealed to the Court of Arbitration for Sport (CAS), arguing the DRC misapplied regulations and miscalculated the training period. The CAS addressed key legal issues, clarifying that FIFA Circular Letters, while not legally binding, reflect FIFA's interpretation of its regulations and serve as guidance. Circular 826 allows adjustments to training compensation if the objecting club proves the indicative amounts are clearly disproportionate, but the burden of proof lies with the club to provide specific evidence, such as invoices or training center costs. Without such evidence, the indicative amounts apply.
The CAS also noted that training compensation cannot be calculated based on an individual club's budget, as per Circular 769, but Circular 799 can assess disproportionality in specific cases. Costs related to agents and scouts were excluded from calculations, as they do not constitute actual training costs. The "value and quality" of the player were deemed irrelevant for assessing disproportionality; instead, the focus should be on the "value of the formation received." Ultimately, the CAS upheld the DRC's decision, confirming Parma had not provided sufficient evidence to justify a departure from the indicative amounts.
Parma later submitted additional documentation, including balance sheets and invoices, but the Panel found these insufficient due to inconsistencies, missing translations, and unsubstantiated claims. The Panel also rejected Parma's argument that the player's later transfer value should influence compensation, emphasizing this falls under the solidarity mechanism, not training compensation. The CAS affirmed the DRC's decision, ruling Parma was entitled only to the initially agreed EUR 205,000, which Manchester United had already paid. The appeal was dismissed, and all other requests for relief were rejected.
The case underscores the importance of clear documentation and adherence to FIFA's regulatory framework in disputes over training compensation. It highlights the challenges clubs face in proving actual training costs and the necessity of providing robust evidence to justify deviations from FIFA's indicative amounts. The decision reinforces the principle that training compensation is based on standardized calculations, with adjustments permitted only in cases of clear disproportionality, supported by concrete evidence.