CAS Case Digest · Verified against the full award text

CAS 2019/A/6096 — FC Lugano SA v. FC Internazionale Milano S.p.A.

"Lugano v. Inter (Koffi training compensation)" · CAS confirmed EUR 235,000 training compensation owed by Lugano to Inter, holding that a loan does not break the training compensation chain.

What happened in Lugano v. Inter (Koffi training compensation)

FC Internazionale Milano signed Ivorian player Yao Guy Eloe Koffi (born 20 January 1996) from Parma in January 2012 for EUR 1,000,000. Inter loaned Koffi to Serie B club Crotone for the 2015/2016 season free of charge, paying Crotone up to EUR 70,000 in development fees for fielding him. After returning to Inter, Koffi played no official matches in 2016/2017 and terminated his contract on 7 June 2017 invoking sporting just cause. He then signed with FC Lugano SA. Inter blocked the ITC and claimed training compensation. The FIFA DRC sub-committee on 7 June 2018 ordered Lugano to pay EUR 235,000 plus 5% p.a. interest from 18 September 2017. Lugano appealed to CAS arguing: (1) the loan to Crotone broke the training compensation chain; (2) Inter, not Lugano, was the beneficiary of Crotone's training; and (3) Koffi had completed his training before age 21. Sole Arbitrator Ulrich Haas dismissed all three grounds, confirmed the EUR 235,000 award. The case matters because it consolidates the settled CAS rule that a loan does not interrupt the training period and that the receiving club at the end of the player's career path bears the full training compensation obligation.

Procedural history of CAS 2019/A/6096

On 10 October 2017, Inter lodged a claim before the sub-committee of the FIFA Dispute Resolution Chamber requesting training compensation of EUR 242,136.99 plus interest from Lugano. Lugano rejected the claim in its entirety. On 7 June 2018, the sub-committee partially accepted Inter's claim and ordered Lugano to pay EUR 235,000 plus 5% p.a. interest from 18 September 2017, together with CHF 15,000 in FIFA procedural costs. The grounds of the Appealed Decision were communicated on 21 December 2018. On 10 January 2019, Lugano filed a Statement of Appeal with CAS under Articles R47 and R48 of the 2019 CAS Code, seeking to set aside the decision in full or, subsidiarily, to have the training compensation substantially reduced. CAS constituted a sole arbitrator on 19 February 2019. A hearing was held in Milan on 4 June 2019.

Key holdings in CAS 2019/A/6096

• A loan of a player does not constitute a 'subsequent transfer' under Article 3(1) Annex 4 FIFA RSTP and therefore does not break the training compensation chain, leaving the club of origin entitled to training compensation for all periods it effectively trained the player, excluding only the loan period itself.
• Domestic federation rules (here FIGC regulations) govern only domestic transfers and do not affect the application of the FIFA RSTP in an international training compensation dispute.
• The fact that the loaning club (Inter) may have benefitted from training provided by the borrowing club (Crotone) does not reduce the training compensation obligation of the new club (Lugano), because the entire period from first registration to contract termination is treated as one training period.
• The burden of proving early completion of a player's training period before age 21 lies with the party asserting it, and the standard is high: it must be 'evident' that training was completed, which was not met where the player was a regular starter only in Serie B, was not called up for his national team, and was not a regular starter even for Lugano at ages 21/22.
• Training compensation of EUR 235,000 was correctly calculated at EUR 60,000 per year (Lugano being a category II club) over approximately 3 years and 11 months of effective training by Inter (1 July 2012 to 13 July 2015 and 1 July 2016 to 7 June 2017).

How the CAS panel reasoned

The Sole Arbitrator addressed three limbs in sequence. On the loan-breaks-chain argument, he surveyed the CAS jurisprudence and preferred the line established in CAS 2013/A/3119 and consistently confirmed thereafter (CAS 2015/A/4335, CAS 2016/A/4543, CAS 2017/A/5090, CAS 2014/A/3620, CAS 2014/A/3710) over the earlier CAS 2012/A/2908 ('Panionios'), which later panels had explicitly overruled. The policy rationale was that treating loans as chain-breakers would deter clubs from loaning young players, harming player development. On the beneficiary argument, the Arbitrator held that the loan was an internal arrangement between two Italian clubs and that Lugano, as the ultimate beneficiary of the entire training investment, bore the obligation. On early training completion, he applied a multi-factor test drawn from CAS 2017/A/5090 and CAS 2006/A/1029: regular appearances in Serie B were insufficient given the lower level compared to Serie A; Crotone did not exercise its purchase option; Inter paid development fees precisely to incentivise fielding; the player was never capped for Ivory Coast; and even at Lugano he was not a regular starter. The Arbitrator stressed that the 'evident' threshold in Article 1(1) Annex 4 FIFA RSTP sets a high bar that was not met.

Why Lugano v. Inter (Koffi training compensation) matters in CAS jurisprudence

This award reinforces the settled CAS doctrine — crystallised in CAS 2013/A/3119 and its progeny — that a temporary loan does not interrupt the training compensation chain under the FIFA RSTP. It also provides a detailed application of the multi-factor 'early training completion' test, confirming that regular appearances in a second-division league are insufficient to meet the 'evident' standard of Article 1(1) Annex 4 FIFA RSTP, and that domestic federation rules cannot override the FIFA RSTP framework in international disputes.

Cases cited in this award

CAS 2012/A/2908 CAS 2013/A/3119 CAS 2014/A/3620 CAS 2014/A/3710 CAS 2017/A/5090 CAS 2018/A/6017

Frequently asked questions about Lugano v. Inter (Koffi training compensation)

Does a loan to another club break the training compensation chain under FIFA RSTP?

No. CAS confirmed in this case that a loan does not constitute a 'subsequent transfer' under Article 3(1) Annex 4 FIFA RSTP and therefore does not interrupt the training period. The club of origin (here Inter) remains entitled to training compensation for all periods it effectively trained the player, excluding only the loan period itself. This principle was first clearly established in CAS 2013/A/3119 and has been consistently followed since.

How was the EUR 235,000 training compensation figure calculated in Lugano v. Inter?

The Sole Arbitrator applied Article 4(1) Annex 4 FIFA RSTP using Lugano's category II status, which carries an indicative training cost of EUR 60,000 per year. Inter was credited for two separate periods: 1 July 2012 to 13 July 2015 and 1 July 2016 to 7 June 2017, totalling approximately 3 years and 11 months. The calculation was 3 + (11/12) × EUR 60,000 = EUR 235,000, matching the FIFA DRC sub-committee's figure exactly.

What standard must a club meet to argue a player completed his training before age 21 in a training compensation dispute?

The standard is high: Article 1(1) Annex 4 FIFA RSTP requires it to be 'evident' that training was completed before age 21. In this case, the Sole Arbitrator applied a multi-factor test including level of competition, salary, national team call-ups, captaincy, and performance at subsequent clubs. Regular appearances in Serie B were held insufficient, particularly because Crotone did not exercise its purchase option, Inter paid development fees to incentivise fielding, the player was never capped for Ivory Coast, and he was not a regular starter even for Lugano at ages 21/22.

Can domestic federation rules (e.g. FIGC regulations) reduce training compensation owed under the FIFA RSTP in an international transfer?

No. The Sole Arbitrator held that the regulatory framework governing international training compensation is exclusively the FIFA RSTP. Domestic rules such as the FIGC regulations govern only domestic transfers and do not impact the application of the FIFA RSTP in an international context. Lugano's argument that Inter had already received or was entitled to domestic training compensation from Crotone, which would create a 'double profit', was therefore dismissed.

Topics: Training compensation & solidarity at CAS

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