The Upper Tier Tribunal (UTT) sitting on HMRC v Murray International Holdings (MIH) has ordered HMRC’s demand for unpaid tax to be reduced substantially. Claims Sir David Murray Employee Benefit Trust should be taxed were dismissed, but the UTT was not prepared to endorse that guaranteed bonus payments paid to Rangers players should not be taxed.
During the First Tier Tribunal MIH acknowledged tax should have been paid on EBTs given to a further five players, who were removed from the judgement (although the tax was never paid). Lord Nimmo Smith’s SPL Inquiry found Rangers guilty of not disclosing side-letters given to players which contractually bound EBT payments and arrangements. The Inquiry issued Oldco Rangers with a fine of £250,000. Newco Rangers agreed to pay all of Oldco’s football debts as a price to gain entry to the SFA and league structure. It is anticipated this fine will be collected in the event the club reaches top flight football.
Rangers did not dispute they operated an illegal Discount Options Scheme, which was uncovered by Craig Whyte’s investigators, when he carried out due diligence before buying the club from Sir David Murray. Tax due on this scheme was never paid.
Once in control, Whyte continued to operate the club’s tax arrangements in similar ethical standards. He failed to pay VAT, PAYE or National Insurance. Several hundred other creditors were left in the lurch as the club was liquidated.
At its heart, this is a morality tale. The first lesson which should be drawn is that it is far better to disclose your tax arrangements to the authorities than to hide them. When Celtic employed Juninho, who had an earlier EBT, they disclosed this fact and subsequent transactions to HMRC (Celtic never issued rule-breaking side-letters either).
Perhaps the most important lesson is not to allow debt to get out of control. Armed with the Discount Options Scheme and tax not paid on contractually guaranteed bonuses, HMRC were legally bound to pursue the club for money the tax payer was due – and will almost certainly never be paid.
Once that train was in motion, the club was at the mercy of its bank. MIH held substantial commercial property assets at this time, when the UK commercial property market took an average 45% nosedive. Then the bank itself (HBOS) was sold, exposing legacy arrangements to full commercial scrutiny.
Even then, even then, Rangers could have used the bonus of Champions League income to either rapidly pay-down their bank debt, or retain as a hedge against the consequences of the on-going tax dispute. Instead Walter Smith returned to the transfer market, spending what he could to keep his nose in front of Celtic.
This was an arrogant and fatal mistake.
When Whyte put his £1 on the table there was nothing the Independent Board Committee could do to dissuade Sir David from selling, but by then all the cards had been played, an insolvency event was on the horizon unless someone coughed up £18m to repay the overdraft, and no one was prepared to do this.
In the unedifying final days the club was reduced to turning, cap in hand, to lifelong adversaries to ask for rule changes which never arrived.
Despite all of this, humility among this lot is scarcer than a fully paid up tax receipt.
It took dozens of people working to promote Rangers on-field activities to kill the club. Those who failed to disclose side-letters, those who allowed debt to get out of control, those who sat on boards which endorsed Smith’s spending knowing the potential consequences, those who campaigned against the people who disclosed Whyte’s background, were all necessary for this outcome. Their reputations are now co-dependent
Celtic fans, HMRC nor the SFA killed Rangers. None of them* knew about the Discount Options Scheme, the undisclosed side-letters, the unpaid VAT, PAYE or NI bills. None of them decided to spend more than was prudently possible.
Killing Rangers was an inside job. The biggest rivalry in football is gone; we won, by an avalanche of own goals.
*apart from SFA president Campbell Ogilvie, who knew exactly what was going on.
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My dad John Mulreany died this morning. His passions were his family, the church, Lochee Harp FC and Celtic FC. He is responsible for a family steeped in Celtic.
RIP John and thank you for everything.
quonno
19:34 on 10 July, 2014
__________________
The Celtic fans swallowed John Reid’s stuff about
“The Holy Wullies…..”
“We wont be sitting at the back of the bus anymore.”
An un-named spoksman – “We’re surprised,” re: LNS
PeterLawwells – Rory Bremner jokes etc….
Aint no cuties amongst the support these days, they’re
all on the board.
Thanks to the people who bid 11 million for Ross McCormack and also to the Brazil team for giving me such laughs recently.
Some Celtic men still actually want us to join the EPL madhouse. Madness.
benjybhoy mul
19:40 on
10 July, 2014
My dad John Mulreany died this morning. His passions were his family, the church, Lochee Harp FC and Celtic FC. He is responsible for a family steeped in Celtic.
RIP John and thank you for everything.
…………………………
sincere condolences to you and yours ….rest in peace John
neil canamalar lennon hunskelper extrordinaire
19:33 on 10 July, 2014
Corkcelt,
I think the dilemma here is about how you meet him, as an honoured guest or the evil.
——–
Take his forked tail and stab him in the eye. I would suggest for both deils in question.
In practice that would involve a cold, straight down the line ‘welcome’ to the club for our ‘first ever game against each other.’
Proper recording of the inevitable sectarian bile and damage that will follow. And pursuing the new club and those responsible to make amends. A bit of focus, so to speak.
I hold out hope for Res12 because of the faith and respect I gave for its authors. This – or something else – needs to lead to justice finally bring seen to be done in the corridors of SFA and SPL.
Time to act like we’re not at the back of the bus.
On the field we need to humiliate them at every given opportunity and make 7-1 something the become well used to.
And where do we come into all of this? I hate their sectarian bile. I hope we never play them again. But if 11 Bhoys in Hoops are saving the FOD then I wouldn’t want them doing so alone.
HH jamesgang
quonno
19:32 on
10 July, 2014
I for one stayed to what was a very bitter end.
Bitter though it was, I have always believed it to be the moment that it dawned on Robert Kelly that the job was too big for him.
*I was in St Kessog’s chapel hall that night…EDB might have been there….. and our wee curate Father O’Rourke in an effort to console us said “wait till that wee bhoy Johnstone gets older and things may change…I don’t think even he believed that at the time.
benjybhoy mul
19:40 on 10 July, 2014
___________________
Thoughts and prayers for all concerned.
John Mulreany RIP
benjybhoy mul
May your Father Rest in Peace Mate and May your family be comforted at this time..
HH
Best wishes Benji. Most of us probably owe our love of Celtic to our fathers.
neustadt-braw
benjybhoy mul
Prayers for you both Bhoys. Apols that my intemperate post crossed over much more important matters.
HH jamesgang
benjybhoy mul
19:40 on
10 July, 2014
My dad John Mulreany died this morning.
*RIP tae yer da son.
benjybhoy mul
____________
Sad news pal. So sorry.
Deepest thoughts for all
who are close.
RIP John
Kevjungle
If you do not understand the difference between the answer at a Q&A session and a shareholders resolution then that would explain why you made your point.
John Mulreany – YNWA – RIP
Morrissey the 23rd 13:32 on 10 July, 2014
http://www.youtube.com/watch?v=ntHLjrw9sVU
http://vimeo.com/98819327
I’m going to the @asteriskyears premiere. I’d like fellow CQNers to go to.
To buy a ticket. Join ‘Paul Larkin Books’ on Facebook or if there are any tickets left, there will be a public sale tomorrow at 9am. See @paullarkin74 for more details.
#WeStillWon
http://vimeo.com/85719393
……………
Hope the premiere goes well, more importantly that the film delivers.
HH
benjybhoymul
Please accept my most sincere condolences on your loss today.
John Mulreany and his family will be in my thoughts and prayers.
When you can, perhaps you could tell us a wee bit more about him.
God bless.
neustadt-braw
Prayers said for your Dad’s recovery!
Take care and God bless.
Condolences benjybhoy, R.I.P. John Mulreany, May Heaven be your bed.
Benjybhoy,
Sincere condolences and a prayer for you, your family and all who loved your dad, in this sad time, may his light never grow dim in your heart.
RIP Mr Mulreany
benjibhoy may your father rest in peace.
I used to live about 5 mnts away from harps ground.
Best Wishes to Neustadt-Braw, Will say a wee prayer for your Dad tonight. Please God he will be OK.
Late back in tonight, how were the facts of the Edmiston Tax Dodgers dealt with on the scoddish news?
HH
philbhoy
I’m too raw just now, emotionally drained after driving from Glasgow to Dundee at 3.00 am this morning, getting into Ninewells hospital to see him pass away (peacefully) after the last rites and putting a start to the funeral arrangements.
Maybe some other time.
Thanks to all who offered their condolences.
benjybhoy mul
God bless and take care.
benjibhoy mul
Condolences to you and your family.
HH John Mulreany
Benjibhoy mul
So sad to hear the news about your Da.
May he rest in peace
Benjybhoy. Sincere condolences to you and all your family at the loss of your dear dad. RIP. Will remember to pray for him at Mass tomorrow.
Iron Mountain, Livingston £1,271.16
That’s where the corpses are.
Can you no just see somebody cringing in a minute
Benjybhoy
Sincerest condolences on your loss – always remember that when you feel like it we will all be here to chat- argue – debate – because that’s what we do through love of our club and families!
HH
R I P John Mulreany
Am sure your bhoy will keep the Celtic flame burning in your memory
YNWA
http://www.scotsman.com/sport/football/spfl-lower-divisions/rangers-administration-campbell-ogilvie-full-of-regrets-and-wonders-if-he-could-have-done-more-1-2181094
benjybhoy mul,
Sincere condolences to you and your family on the passing of your Dad.
AR
Looking forward to Tom Baa English’s report being Awe nawed.
neustadt braw,
Hope your Dad makes a speedy and braw recovery.
AR
R I P John Mulreany , thoughts and prayers with his family.
YNWA
The people characterised by WATP as the “enemy within” –
..had a “Big Tax Case” deal ready to be settled with HMRC in the region of 12 million..
..but when he/they took it to the “Boys Upstairs” at the Bank he/they were told to focus on the job in hand ie .to get the Bank our of their debt.
Thus ensuring No Deal with HMRC ….
thus backing HMRC into a corner…..
I understand HMRC were very compliant in the early negotiations getting to 12 mill but incandescent when told by the MIH/RFC executive(s) that there was no ability to pay/settle
In addition MIH had a full scale dossier on Agent Green.
So whatever is published on and offline in the next weeks …the die was cast when the organisation that previously funded SDM/MIH extravagances…decided, although it was by then English not a Scottish senior management Bank and had gotten rid of its (infamous RFC Loyal gang) purported Rangers leaning management…set on a course that is now history…
In any event…the Trading Company and Holding Company were technically insolvent..
So UTT aside it was all over then…..
What has happened since has only added to the jollity and sweetness
I look forward to days/weeks/years of Pravdian re-writes of insolvency history!!
http://www.philmacgiollabhain.ie/double-act/#more-4836
HH jamesgang