The case CAS 2020/A/7092 involved a dispute between Panathinaikos FC, FIFA, and Parma Calcio 1913, centering on whether Parma Calcio 1913 should be considered the sporting successor of the bankrupt Parma FC and thus liable for its unpaid debts. The dispute originated from a 2014 FIFA Dispute Resolution Chamber (DRC) decision ordering Parma FC to pay Panathinaikos €467,000 in training compensation for a player. When Parma FC failed to pay and subsequently went bankrupt in 2015, Panathinaikos sought to enforce the debt against Parma Calcio 1913, arguing it was Parma FC's sporting successor. The Court of Arbitration for Sport (CAS) panel addressed several legal questions, including the criteria for determining sporting succession under Article 15 of the FIFA Disciplinary Code (2019 edition), which outlines factors such as headquarters, name, legal form, team colors, players, ownership, and competition category.
The panel emphasized that each case must be evaluated individually, rejecting rigid precedents in favor of a flexible, fact-specific approach. Parma Calcio 1913 was founded shortly after Parma FC's bankruptcy and admitted to Serie D, Italy’s highest amateur league. Panathinaikos argued that Parma Calcio 1913 was Parma FC's successor due to similarities in name, colors, logo, stadium, and historical references. However, FIFA and Parma Calcio 1913 countered that the new club was a distinct legal entity with different ownership, players, and financial structure, starting in amateur leagues rather than inheriting Parma FC's professional status. The panel noted significant differences, including the lack of continuity in players, shareholders, and technical staff, as well as Parma Calcio 1913's failure to claim credits owed to Parma FC.
Despite some connections, such as Parma Calcio 1913's public reliance on Parma FC's history and the use of similar branding, the panel concluded that the majority of important elements pointed against succession. The delay in Panathinaikos' complaint until 2019, four years after Parma Calcio 1913's establishment, also undermined its claim. Ultimately, the panel upheld FIFA's decision, ruling that Parma Calcio 1913 was not the sporting successor of Parma FC and thus not liable for its debts. The case underscored the complexity of determining club succession in sports law, highlighting the need for a nuanced evaluation of facts and applicable regulations to prevent abuse while allowing legitimate reorganizations. The ruling reinforced the principle that successor liability depends on a holistic assessment of multiple criteria rather than any single factor.