The case involves a dispute between Associazione Calcio Venezia 1907 (Venezia) and Clube Atlético Mineiro (Atlético Mineiro) over training compensation for a player, referred to as A., who was registered with Atlético Mineiro from August 1995 to December 2002. The FIFA Dispute Resolution Chamber initially ruled that Venezia owed Atlético Mineiro €540,000 as training compensation for A.'s development between ages 15 and 21, based on UEFA's Category 1 rates. The Chamber rejected Atlético Mineiro's additional claim for $5,000,000 under Brazilian labor law, stating no transfer compensation was due after the player's contract expired. Venezia appealed to the Court of Arbitration for Sport (CAS), arguing Atlético Mineiro failed to prove the duration of A.'s registration and the costs incurred during his training. Venezia also contested the calculation method, seeking a reduced amount of either $250,000 or €300,000.
The CAS panel addressed three key issues. First, it ruled training compensation is not limited to complete years, as regulations do not exclude partial periods. Second, it found a club cannot claim compensation for a loaned player unless it proves the costs incurred during the loan. Third, it confirmed the legal interest rate of 5% per annum under Swiss law applies in the absence of a contractual clause. The panel upheld the FIFA decision, emphasizing Atlético Mineiro was entitled to compensation for the effective training period, regardless of whether it spanned full years. It also clarified the $5,000,000 claim under Brazilian law was invalid under FIFA regulations, which do not recognize transfer fees after contract expiration. The CAS dismissed Venezia's appeal, affirming the €540,000 compensation and 5% interest rate for late payment.
The ruling reinforced FIFA's principles on training compensation and the limitations of claims based on national labor laws. It underscored the importance of proving actual training costs and adhering to FIFA's framework for resolving disputes. The panel also examined whether A.'s registration with Atlético Mineiro was properly established, concluding sufficient evidence demonstrated his registration from August 1995 to December 2002. The calculation of training compensation was based on FIFA guidelines, which stipulate compensation is due for training between ages 12 and 21, unless the player completed training earlier. The panel affirmed the validity of FIFA Circular Letter No. 826 as a basis for calculation, aligning with previous CAS decisions.
The panel rejected arguments that short or interrupted training periods should be excluded, emphasizing the system's purpose of rewarding clubs for their investment in player development. It ruled Atlético Mineiro could not claim compensation for the period A. was loaned to another club in 2001, as it failed to demonstrate bearing training costs during that time. Consequently, the effective training period was reduced to five years and five months (August 1995 to December 2000). The compensation was calculated at €90,000 per year for a Category 1 club, adjusted for the actual training duration. The panel dismissed claims of a fraudulent transfer, as no evidence showed the transfer deprived Atlético Mineiro of rightful compensation. Neither party provided concrete evidence to support their claims about the compensation amount, leading the panel to uphold FIFA's indicative amounts.
The final decision required Venezia to pay €487,500 to Atlético Mineiro, plus 5% annual interest starting from 30 days after A. signed with Venezia (2 March 2003). All other claims and counterclaims were dismissed. The ruling aligns with CAS jurisprudence and FIFA regulations, ensuring training compensation reflects the player's development period and the clubs' respective categories. The case highlights the complexities of international sports disputes, particularly regarding player transfers, training compensation, and jurisdictional conflicts between national and international regulations. The decision underscores the importance of adhering to FIFA's framework and providing evidence to support claims in such disputes.