Chelsea are to be handed a huge unpaid tax bill next month after inspectors finally unravelled the full extent of liabilities left under Roman Abramovich's ownership.
As disclosed by Telegraph Sport in June, Todd Boehly was permitted to hold back more than £100 million to cushion the new regime from costs raised at the 11th hour of the takeover.
Club executives under the previous ownership had been forced to disclose significant unforeseen liabilities just days before the sale, initially worth a total of £2.5 billion.
Chelsea have always made it clear they have not breached the profit and sustainability regulations of either the Premier League or Uefa.
However, under the sanctioned Russian's ownership, Chelsea received funding via a complex series of parent companies in which tax liabilities had become increasingly difficult to unravel. HMRC and the club have been in regular contact in recent weeks and inspectors are now believed to be ready to issue a final bill covering previous years.
Checks by regulators after the club effectively became a frozen asset in March prompted Chelsea to voluntarily declare huge unpaid liabilities to Boehly before the deal was completed at the end of May.
The deal was completed in such a short timeframe that the liabilities were negotiated as a contingency. As a result, a reduced sum of around £2.3 billion remains sitting in a Government holding account. Three months on from the deal, Mike Penrose, the former Unicef chief executive tasked with using the funds for a foundation for war victims, has only so far received fees to cover the legal process in setting up the new organisation.
Of the Chelsea tax arrangements, a club spokesman said when contacted by Telegraph Sport: "It is not unusual in these types of transactions, particularly deals completed in an accelerated timeframe, to withhold an amount related to any unforeseen liabilities that may arise from transactions that occurred prior to the sale."
Last year's annual accounts for Fordstam Ltd show Abramovich injected around £150 million and withdrew around £130 million, to end the year loaning the club an overall £19.9 million, and taking the total related-party loans to £1.514 billion. The loans were due to be repaid to Camberley International Investments Ltd, a Jersey-based entity which had been the target of a raid by authorities freezing billions of pounds of the Russian's assets. Other connected companies to Fordstam include Stamford Bridge Projects Ltd.
Following a fraught three-month sale saga, Boehly had made commitments totalling £4.25 billion, including the purchase price and subsequent 10-year spending commitments. His consortium fought off 11 serious rivals in a process overseen by the Government after Abramovich formally put the club on the market on March 2.