A total of 302 footballers or managers have "non-domiciled" status in the UK and a further 67 claim they are "not resident", according to UK Treasury documents released under the Freedom of Information Act. Non-domiciled players include Cristiano Ronaldo and Owen Hargreaves of Manchester United, said The Sunday Times, and almost half the players in the Premiership are from overseas. David Beckham's spokesman said that he was non-resident in the UK for tax purposes but would pay tax on his earnings in America. Sven-Goran Eriksson, the former England coach who is now managing Manchester City, is thought to be a beneficiary of the tax regime. Non-domiciled players, said the newspaper, must be born abroad or have parents born abroad. Typically they sign multiple contracts for their services. One contract pays the player for matches in the UK. They have another contract for their "global image rights". A third contract pays for any foreign appearances. UK tax is typically paid only for money earned on the first contract, with money earned on the other contracts paid tax-free to an offshore jurisdiction. In contrast, players in Spain must pay tax to the Spanish government on their worldwide earnings. UK Prime Minister Gordon Brown pledged to close the resident non-domicile regime while in opposition pre-1997 but has so far failed to act despite the scheme being "under review" by the UK's Treasury since 2002. A memo from a Revenue official in May 2005 states: "Quite a lot of the ND (non-domicile) and NOR (not ordinarily resident) cases dealt with ... were either professional footballers or professional football coaches/managers. Top football players and managers earn large amounts of money and so may well have relatively complex tax affairs." Footballers are the latest group to be identified as beneficiaries of loopholes offered to the global super-rich by the UK. The heads of private equity firms have recently come under criticism after it emerged they paid tax at a rate of less than 10 per cent on multi-million-pound earnings. The Treasury documents reveal that there were 77,000 non-domiciled people in Britain in 2002, avoiding an estimated £1 billion ($2 billion) in tax. The number is understood to have risen to almost 200,000 since then.