The Court of Arbitration for Sport (CAS) issued a ruling on 23 July 2013 in a dispute between Konyaspor Kulübü Dernegi and Ituano Futebol Clube concerning training compensation for the transfer of a Brazilian player. The case centered on whether Ituano qualified as the "former club" entitled to compensation under FIFA's 2005 Regulations for the Status and Transfer of Players. The player had a complex registration history, including a brief and disputed one-day registration with Olaria Atlético Clube, which was later revealed to be a sham designed to circumvent training compensation rules. The CAS panel, comprising Prof. Massimo Coccia, Mr. Pedro Tomás Marqués, and Mr. João Nogueira Da Rocha, emphasized that training compensation is intended to reward clubs that genuinely invest in a player's development. They ruled that Olaria could not be considered the "former club" because the player neither trained nor played for them, while Ituano had substantially contributed to his development from ages 16 to 21.
The case involved allegations of fraudulent activity, including a forged International Transfer Certificate (ITC) dated July 2006, which contained discrepancies such as an incorrect player registration number and reference to a defunct federation. The CAS panel determined the document was fraudulent, though Konyaspor denied involvement. The player's contractual status was further complicated by a Brazilian labor court ruling that allowed him to terminate his contract with Ituano prematurely. The panel also addressed the burden of proof for demonstrating a player's completed training period before age 21, which lies with the club making the claim. Ituano failed to provide sufficient evidence of the player's first-team appearances, but the panel still ruled in their favor, as Konyaspor benefited from the player's training.
The CAS upheld the FIFA Dispute Resolution Chamber's decision, requiring Konyaspor to pay Ituano €250,000 in training compensation, calculated based on UEFA category 2 club training costs. The ruling clarified the criteria for determining a "former club" and reinforced the importance of genuine investment in player development for entitlement to compensation. The case highlighted the need for transparency and integrity in transfer documentation and underscored the consequences of attempting to manipulate regulations to avoid financial obligations. The CAS dismissed all other requests or motions by the parties and ordered Konyaspor to pay 5% annual interest on the compensation amount from 7 November 2012 until the payment was settled. The decision affirmed the principles of fairness and accountability in football transfers, ensuring clubs that invest in player development are duly compensated.