The Court of Arbitration for Sport (CAS) ruled on a dispute between FC Lugano and FC Internazionale Milano (Inter) concerning training compensation for a player under FIFA’s Regulations on the Status and Transfer of Players (RSTP). The case involved a player who transferred from Parma to Inter at age 16 and was later loaned to FC Crotone during the 2015/2016 season. Inter argued that the loan period should reduce the training compensation owed to Lugano, but the sole arbitrator, Prof. Ulrich Haas, rejected this, stating that loans do not interrupt the chain of seasons for which compensation is payable. The arbitrator emphasized that training compensation covers the entire development period unless clear evidence proves the player completed training before turning 21. Factors like regular appearances, salary, and national team inclusion were considered, but none conclusively demonstrated early termination of training.
The player’s transfer history included a €1 million move from Parma to Inter in 2012, followed by a loan to Crotone in 2015, where he played extensively. Negotiations for a subsequent loan to Nice collapsed due to the player’s refusal to leave Inter. During the 2016/2017 season, the player remained with Inter’s first team but did not play, leading him to terminate his contract for "sporting just cause." Inter countered by filing a claim for €4.7 million, alleging unjustified termination. FIFA’s Dispute Resolution Chamber (DRC) initially ruled against the player, ordering him and Lugano to pay Inter €133,532. Lugano appealed to CAS, disputing Inter’s entitlement to training compensation, particularly for the loan period.
The CAS upheld the principle that loans do not constitute subsequent transfers under FIFA’s RSTP and do not interrupt training periods. It rejected Lugano’s argument that the player’s training was complete before his 21st birthday, noting that Serie B appearances did not definitively prove readiness for top-tier football. The arbitrator calculated the compensation at €235,000, plus interest, based on Lugano’s category II status and the player’s registration periods. The ruling reinforced FIFA’s stance on protecting training clubs’ rights while allowing young players to gain experience through loans.
In a related proceeding, CAS dismissed Lugano’s appeal, confirming Inter’s entitlement to compensation for the entire training period, excluding the loan stint. The decision highlighted the high threshold for proving early training completion and clarified that domestic regulations, such as those of the Italian Football Federation (FIGC), do not override FIFA’s RSTP in international transfers. The arbitrator also ordered Inter to reimburse Lugano for procedural costs, underscoring the financial and legal complexities of player transfers and contractual disputes. The final ruling emphasized the importance of compensating clubs for player development and maintaining consistency in interpreting FIFA’s regulations.
The case illustrates the challenges in determining training compensation, particularly when loans are involved, and reaffirms the strict criteria for proving early termination of a player’s training period. The decision serves as a precedent for future disputes, ensuring clarity and fairness in the application of FIFA’s rules.