Articolo 18-bis Legge 91/1981 (Article 18B of Law no. 91 of 1981), also known as Decreto Spalmadebiti (Debt-Rubbing Decree) and Decreto Salva Calcio (Save Football Decree), is an Italian decree-law introduced in 2003 by Law no. 27 of 2003, itself ratified the Law no. 282 of 2002 issued by the then Prime Minister of Italy and owner of AC Milan, Silvio Berlusconi,[1] for which reason the law was considered among Berlusconi's many ad personam laws and an example of sportwashing. Officially known as the Tax Law Decree: 2.5% Tax Shield, Disposal of Properties and VAT Numbers, it was issued by the second Berlusconi government on 24 December 2002 and then converted into law by the Italian Parliament on 21 February 2003 with the Law no. 27 of 2003.[2]
The law, which received widespread criticism including from the European Union,[3] allows football clubs to defer the amortization expense of intangible assets (player contracts) into 10 equal annual installments. Generally speaking, transfer fees paid to other clubs were capitalized as intangible assets. In accounting, tangible assets were depreciated and intangible assets amortized. At that time, Italian clubs had broken the world transfer record several times. Most clubs relied on player profit as a revenue source, with cash-plus-player deals the most popular method of increasing profit. For example, Juventus FC signed Gianluigi Buffon and Lilian Thuram for a total of ₤180 million (€92.96 million); Parma Calcio also received Jonathan Bachini for an undisclosed fee and Juventus earned €10 million on Bachini.[4]
In some cases, high-priced player trades were used to increase short-term profit, stressing future budgets. Vratislav Greško, who was signed for one year by FC Internazionale Milano for DM9.5 million (€4.857 million), was sold to Parma in 2002 for €16 million; Matías Almeyda, who joined Parma with Hernán Crespo, also sold from Parma to Inter for €16 million. Both Greško and Almeyda left the club after one and two years, respectively, for an undisclosed fee and free transfer. A similar situation occurred to Parma and AS Roma in 2001: Amedeo Mangone, Paolo Poggi, and Sergei Gurenko were priced at a total of ₤65 million (€33,569,698) in a trade with Diego Fuser, Raffaele Longo, and Saliou Lassissi. In practice, Fuser played only briefly for Roma and Gurenko only briefly for Parma. Roma also traded with other clubs in June 2002 (the end of the 2001–02 financial year), including Luigi Sartor (€9.5 million) for Sebastiano Siviglia (€9 million).[5] Inter (€-319 million), Milan (€-242 million), Roma (€-234 million), and SS Lazio (€-213 million) were the most indebted clubs,[6] while ACF Fiorentina declared bankruptcy by insolvency in 2002. All professional clubs in the country, with the exception of Serie A's Juventus and Serie B's UC Sampdoria, had relieved its debt with this law.[7]