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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Stepdaughter and get pal transferring litres of bevvy from glass into plastic bottles for T in the Park.
Her pal reckons the fact that it’s Malibu and voddie will make it less liable to be knicked from their tent than their pals’ more colourful concoctions!
Oh the sweet naive innocence of youth and 1st time festival goers!
HappyToBeOldCSC
HH jamesgang
benjybhoy mul –
just read back. Condolences and prayers on the loss of your father. RIP
Get = her.
67..,
Can you explain the commendable stewardship bit ?
From what I understand of that, they told us they wont gamble with £6M signings but waste that £6M on 5 or 6 £1M signings gambling on a big pay off. Explain to me how thats not gambling ? Please.
As for my intolerance, my intolerance in supporting the Celtic support is my Achilles heel, I will never stop trying to find the good in every action of our support. Sometimes I can see none, for example when I read hypocrites condemn politically poignant statements by the support because it does not align to their own political outlook yet haver on about our roots and the biggest political statement “charity” that anyone can make sticks in the craw.
More than a club but no more than a Plc, what a meesage.
317 needed
67Heaven … I am Neil Lennon ….The angels are with Wee Oscar in Heaven.. Ibrox belongs to the creditors @ 21:15
As jamesgang just reposted. It seems it is only a rumour.
Benjibhoy mul
condolences to you and yours
HH
Benjybhoy
My sincere condolences.
May eternal light shine upon your father.
May he rest in peace.
NB
Will say a wee prayer for a full recovery.
Benjibhoy
My condolences and I wish you all the strength you will need to draw on over the next few day
::::::::
neustadt-braw
19:34 on 10 July, 2014
aye some weeks are no sae braw ….if anyone feels inclined please say a wee prayer for my Dad ,took a turn then felt better so chased the para-medics.but rushed to Ninewells the next morning ….91 is a worrying age he says …and as Dad would also say we are Celtic we fear nothing ….
Braw
I wish you and your family all the best and hope your Dad gets better soon.
I dont remember anyone ever turning up at Celtic Park with their altar boy garb, why is it that some think because they have matured and moved on from the young mhans attitude that all the new young mhen should not be allowed to mature with the same patience they were afforded ? Can somebody explain that please, old foggies will always be old foggies and most became old foggies through experience and fear, fair enough they want to impart their experience but who the copulation said they were allowed to impose it ? Make your own mistakes else you’ll learn nothing.
Neustadt Braw
A wee prayer said for your Da.
God bless
Paul a super piece, thank you! Your efforts are very much appreciated, perhaps we should all be making some small contributions to CQN to make sure its safe and in their face!
Scotland’s Orange Order Wants You to Vote No to Independence
http://www.vice.com/en_uk/read/orange-order-independence-liam-turbett-567
Neustadt Braw
Hope your Dad recovers.
HH
neustadt braw
hope your dad gets better soonest
HH
My view on the independence debate.
It doesnt matter if we’re governed from London, Edinburgh or Brussels governance is a sham democracy is bullshit but the best option available. I’ll vote for anyone that kills the telly.
Neil
Simon Cowell and those wee smug bassas Ant n Dec killed the telly for me.
Please don’t vote for any of them. Please!!!
HH jamesgang
James..,
Most people experience and communication skills are now bullshit they seen on the telly
Why this ongoing suggestion that if you vote no to independence you are somehow in bed with the OO, Lulu, the Bay City Rollers and wee Jimmy Krankie?
Bonkers!
Eduardo…………..
for the mouth-breathers it begins and ends with the fleg – The jeck………
They are no weel kent for their in-depth philosophy.
Neil C
Or on bl&&dy iPhones mhate….
….was in turkey last week with the family. Completely deaf in one ear with water from the pool.
Saw a family sitting beside is where all of them were heads down on their pesky phones n tablets!
The world is Donald ducked I announced, in a way that I think you’d have approved of.
The reaction of the girl sitting closest toe told me,
a) despite looking furrin’ she could understand Weedgie
And
b) my deaf lugs were causing me to shout!!!
Nae time or space to think nowadays. And a vacuum filled with Cowell and Murdoch. I’m with you brother!
Now need to go. To watch some telly with the mrs!
;-)
HH jamesgang
BENJYBHOY
NEUSTADT-BRAW
Best wishes going forward at a very hard time for you both,and to your respective families.
HH
How Much fur a Forster?
Here, a Forster Freeze, which Ah simply Adore..coasts..
A Dollah Fifty!
O.K… so we ur No talkin’ aboot.. Ice Cream Cones..here~~~~
In oor Case..
Ah wid Start the Biddin’ at Eight Million.. wi a Reserve Price o’
Ten Million.
Ten Million, wid Dae Me.
But, If the Newsies ur right.. then.. we Could See.. a Twelve Million Bid comin’ In.
There ur a Loata Clubs oot there ..it Seems.. who ur very Interested in jist Where Forster’s Final Resting Place.. May be,
Ah wid Hope it is In Spain.. but, Duntocher, wid dae,me fine.. If
They Come up wi’ the Twelve Mill… Ah really hiv Nae Fixed Preference~
Now ye know.
Kojo
Still, Laughin’
JAMESGANG
You could count on the fingers of one hand how many times my telly has been on since Christmas.
Never been a huge fan. I remember the battles I had in the late 90s convincing the TV licence people that I wasn’t breaking the law,I didnae have a telly!
I eventually won that one by telling them that in fact,THEY were breaking the law by accusing me of committing an illegal act.
Happy days,if you’ll pardon the TV pun….
Kojo
If we sell la gran murala will we buy a quality replacement or go with Craig Gordon which is a big gamble ?
Think I know which
jamesgang (and anyone else, obviously) –
I think Ant & Dec are wonderful. Honestly!
rwe, noticed you are posting. Spoke with MG today;the wheels are in motion and the will is there. Just need the alignment to fall correctly… Regards & Hail Hail… TBM… Love your nomme de plume BTW; a great, brave and articulate journalist/writer…
thank you all for your prayers and best wishes …..Dad will know of it ….goodnight one and all ….be thankful of what we have and cherish the love ….
nickinglinesismyfortecfc …..Braw
D D
I see Fanning had another 2 winners today. And a close 2nd too
jude2005 is Neil Lennon \o/
22:31 on
10 July, 2014
D D
I see Fanning had another 2 winners today. And a close 2nd too
——————————————————–
Saw that this morn mate……..then forgot to put on :O(
Does any Bankie know what is on fire in the town?
Huge pall of black smoke from the Clyde near Whitecrook?
hail hail ……….https://www.youtube.com/watch?v=Awh46Dgf5Lo
braw
TheBarcaMole
Thank you for your help with this, and hopefully it comes off ok.
Sometimes that the man himself is actually the Invisible Man :o)
His best work for me is the short story that was released 3 years after he died. Too controversial to be published when he was alive.
“Party down at the Square” It still horrifies me.
http://www.scribd.com/doc/92624587/A-Party-Down-at-the-Square-Text
HH and thanks.
Just tasting a bottle of Hobgoblin beer here out of Lidls nice btw!!!! 99p 500ml
“Sometimes it seems that the man himself is the Invisible Man.”
Jude
Thank you, you wise horse man. Got them on a lucky15. :)))
neil canamalar lennon hunskelper extrordinaire
21:29 on 10 July, 2014
Latest on Res 12 ……..?