Hull City football club are embroiled in a tax dispute over image rights payments relating to former midfielder Geovanni Gomez.
Club bosses have challenged tax decisions made by HM Revenue and Customs officials
Detail of the dispute has emerged in a specialist judge's ruling on preliminary issues following a tribunal hearing in Manchester.
Judge Malcolm Gammie said the dispute centred on payments made to a company which gave Hull rights to use the Brazilian's image.
Geovanni, now 37, played for Hull between 2008 and 2010, the judge heard.
His previous clubs include Barcelona and Manchester City.