FIFA’s $20 Billion Question: Can The World Cup Have Private Owners?

With the confetti from the last World Cup barely cleared from the pitch, FIFA has found itself at the center of another controversy. This time the dispute isn’t about where the World Cup will be played, who qualified for the tournament, or whether a particular red card was appropriate.

Instead, the fight is over ownership.

Earlier this week, FIFA announced plans to create a new commercial entity, FIFA Forward Enterprise (FFE), that would manage the commercial operations of its main competitions, including the men's and women's World Cups. FIFA would then sell a 21% interest in that company to outside investors. According to FIFA, each member association could receive up to $20 million in immediate funding for special projects, in addition to $20 million in FIFA Forward funding for the 2027–2030 cycle.

(Thrive Capital, founded by billionaire Josh Kushner, the brother of President Trump’s son-in-law, would head up the proposed investor group.)

To move forward, FIFA needs the support of a majority of its member associations, along with the necessary approvals from the 37-member FIFA Council. That doesn’t look like a sure thing.

The proposal has already prompted a fierce response. UEFA, European football’s governing body, says it is prepared to boycott future FIFA competitions if the transaction moves forward. In a post published on Instagram, UEFA said, speaking for its member associations, that “We unanimously and unequivocally reject FIFA’s proposal to transfer ownership interests in the World Cup and other FIFA competitions to private investors.”

The post went on to say, “The World Cup cannot be treated as an investment product. It is one of football's greatest sporting legacies. It has been built over generations by players, national teams and supporters across every continent. No part of it should ever be surrendered to private investors. The World Cup is not for sale.”

The post has garnered over a million likes.

What FIFA is Proposing

Today, FIFA owns the commercial rights associated with its biggest tournaments like the World Cup. Those rights include broadcast agreements, sponsorships, licensing, hospitality, and other revenue streams tied to the World Cup and other international competitions.

Under the proposal, those operations would be transferred into a newly created company known as FIFA Forward Enterprise. FIFA would remain the controlling owner, but it would sell a 21% minority stake to those outside investors, who would then be entitled to a share of the company's future financial returns.

If that sounds familiar, it’s because businesses do this all the time. In the U.S., we’ve seen a similar playbook with private equity, an investment strategy where firms buy stakes in companies or subsidiaries, like accounting firms. The typical approach is to streamline operations and inject capital into the company to grow the business, then sell it—or pieces of it—for a profit.

And while fans know that it’s a money-maker, critics of the proposal argue that the World Cup is more than simply an asset. They see it as the centerpiece of an organization whose mission is to promote and develop football (what we Americans call soccer) around the world. Introducing private investors changes the relationship between the tournament and the organization that oversees it.

How FIFA is Structured

Today, FIFA serves as the international governing body for association football, as well as futsal and beach soccer. Organized under Swiss law and headquartered in Zurich, Switzerland, it has 211 member associations representing countries and territories around the world. FIFA’s stated objectives include promoting and developing football globally, organizing international competitions such as the World Cup, establishing and enforcing the rules and regulations governing the sport, and supporting the growth of football through development programs like FIFA Forward.

Each FIFA member association has one vote in the FIFA Congress, regardless of size. Spain has one vote. So does Cabo Verde. Argentina has one vote. So does Curaçao. You get the idea. The structure reflects FIFA's role as the international governing body for football rather than an organization designed to represent only the sport's largest or wealthiest associations.

Most of FIFA’s revenue comes from competitions, particularly the World Cup. Broadcasting rights account for the largest share, followed by marketing partnerships, sponsorships, licensing agreements, hospitality programs, and ticket sales.

In a typical World Cup, those revenues total billions of dollars. FIFA says the money is used for administration, international competitions, and finance development programs throughout the world. That includes grants distributed through FIFA Forward to member associations for infrastructure, youth development, coaching, and other football initiatives.

Those billions can be confusing because FIFA is a nonprofit association (Verein) organized under the Swiss Civil Code. Being a nonprofit, however, does not mean an organization cannot make money.

The key tends to be whether profit is a primary motive. This is true all over the world. Universities charge tuition and professional associations host conferences, publish journals, and collect membership dues. It’s not the amount of money that matters, but the use and purpose of the money that matters.

In FIFA’s case, its status under Swiss law has focused on its role as the governing body for international football, as well as promoting and developing the sport. The World Cup’s commercial success has been viewed as the means to finance the mission, not as the mission itself.

What the Proposal Could Mean From A Tax Perspective

Every sponsorship agreement, broadcast contract, licensing arrangement, and hospitality package from competitions helps finance FIFA’s operations. That’s why the proposed sale raises more complicated questions than a typical corporate restructuring. FIFA can argue that the commercial success of the World Cup exists to support its broader mission of promoting and developing football. But outside investors could muddy that argument.

The proposed investment doesn’t mean that FIFA would lose its tax treatment under Swiss law. Tax authorities generally understand that exempt organizations must operate in the real world. Commercial activity isn’t, on its own, disqualifying. However, outside investors aren’t buying in because they want to promote grassroots football in Africa or build youth academies in Central America. They are investing because they expect a financial return. That could change not only how FIFA carries out its mission, but what that mission could look like in the future.

FIFA appears to believe it can comfortably remain committed to its mission under the proposal. The organization would continue to own a controlling interest in the new company, continue governing international football, and continue distributing money through its existing development programs. Whether Swiss authorities ultimately agree will depend on the final transaction, the governance documents, and the rights granted to investors—details that have not yet been made public.

World Cup Tax Agreements

Currently, every time a country bids to host a World Cup, taxes are part of the negotiations. Host countries routinely agree to provide FIFA with tax concessions as a condition of hosting the tournament. Those concessions frequently extend beyond FIFA itself to broadcasters, sponsors, contractors, and other entities involved in staging the event. Depending on the agreement, exemptions may apply to corporate income taxes, withholding taxes, and other national or local taxes.

For example, when Brazil hosted the 2014 World Cup, it passed laws providing numerous tax exemptions for FIFA and related entities, a decision that generated considerable political debate. Subsequent tournaments in Russia (2018) and Qatar (2022) also included broad tax breaks as part of the hosting package.

However, the U.S. did not make broad concessions in 2026. Instead, it largely relied on existing tax treaties, withholding agreements, and negotiated relief for FIFA and participating federations. Individual players, coaches, referees, and support staff generally remained subject to U.S. tax on income earned from activities in the United States.

A host country’s decision to exempt FIFA from taxes is tied to the hosting agreement, not because Switzerland treats FIFA as a nonprofit association. Governments have historically justified the concessions on the basis that they were helping bring one of the world’s largest sporting events to their country while working to develop the sport worldwide. If private investors begin sharing directly in the revenue generated by the World Cup, governments may face different political questions.

What if FIFA Were a U.S. Organization?

FIFA is governed by Swiss law, but what if it were instead in the U.S.?

In the U.S., tax-exempt status is based on its mission and purpose. The IRS asks whether an organization is organized and operated primarily to serve an exempt purpose, rather than to generate profits for private interests.

Organizations can earn billions of dollars and own subsidiaries. They can even engage in commercial activities. What they generally can't do is operate principally for the benefit of private parties.

FIFA’s relationship with the U.S. tax-exempt system is not hypothetical. In July 2021, FIFA formed FWC2026 US, Inc. as a Delaware nonprofit corporation to operate the U.S. part of the 2026 World Cup and related programs. The IRS recognized it as exempt under section 501(c)(4) in 2022, and according to its Form 990 (the form filed by nonprofit entities) by the end of 2024, it reported more than $177 million in total assets, along with nearly $183 million in liabilities.

FWC2026 US says its mission is to improve and promote association football globally, emphasizing the sport’s educational, cultural, humanitarian, and unifying values. It does that by organizing competitions and events and by supporting soccer-related development and education programs.

But if the U.S. entity were operated principally to maximize profits for its parent, maintaining its nonprofit status would be more difficult.

A section 501(c)(4) organization is a bit different from a section 501(c)(3) organization. Both are tax-exempt, but contributions to a section 501(c)(4) organization are generally not deductible as charitable contributions, while qualifying contributions to a section 501(c)(3) organization generally are deductible.

Even though section 501(c)(4) organizations are generally more flexible than section 501(c)(3) organizations, they are still subject to IRS rules that prevent private interests from receiving a direct benefit (sometimes referred to as private inurement). Both types of organizations can lose exempt status if they primarily serve private rather than public interests.

That means it would be difficult—if not impossible—for an organization in the U.S., whether exempt under section 501(c)(3) or section 501(c)(4), to maintain its status if it were operated principally to generate financial returns for private investors or otherwise serve private interests.

What Comes Next?

FIFA has some work to do to convince its members to support the proposal.

UEFA’s membership spans the EU as well as non-EU countries like Switzerland, Norway, Turkey, and Israel, and includes England, Scotland, Wales, and Northern Ireland as separate associations. The threatened boycott is not limited to the next men's World Cup and could affect upcoming youth tournaments, followed by the 2027 Women’s World Cup, which begins June 24 in Brazil.

The consequences of a boycott could be significant. Spain is the reigning champion of both the men’s and women’s tournaments, and UEFA’s members include many of the strongest national teams in the world. A World Cup without them would hardly be a World Cup.