Side-letters, of course, had not been registered with the football authorities


The First Tier Tribunal not only delivered a verdict on Rangers tax case, they also nailed the issue facing an SPL Commission on the non-registration of player earnings.  Certain HMRC assessments were upheld and some declined, as we expected.  The findings:

Some payments were taxable and liable to NIC

Some payments were loans to players and “remain recoverable and represent debts on their estates”

Non-registration of side-letters [with the SFA and SPL]was incompatible with both authorities’ policing and disciplinary powers

The appeal “reduced substantially” the tax demand but upheld that “that advances in favour of certain players are taxable and liable to NIC”.  So HMRC can look to recover much of the EBT outgoing from recipients, whereas the tax and NIC elements will perish with the liquidated company.

I didn’t expect the FTT to report on the non-registration of side letters but they were categorical on this:

“Side-letters, of course, had not been registered with the football authorities, the SFA and SPL. The spirit of their rules was that the whole contract terms should be registered. Suspiciously, no evidence was led as to who decided that the benefits in terms of the side-letters should not be registered. Non-registration of side-letters was incompatible with both authorities’ policing and disciplinary powers. For example any fines imposed on players would customarily reflect the disclosed wage. Non- disclosure would thwart the authorities’ powers.”

The report is anonymised and no indication is given as to which elements of the demand were upheld, which were denied, or the quantum of the demand.

Orders are now open for the very first CQN Annual, get it here!

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  1. 67Heaven ... I am Neil Lennon..!!.. Ibrox belongs to the creditors on

    There seems to be more than one way to present any situation ….. Detal should be interesting

  2. From previous topic….



    Devil’s advocate question. If the payments from the EBT are deemed to have been loans, notwithstanding the issues around repayment of said loans, how can the football authorities consider these to have been payment for playing football? Therefore does the question about illegal registration not become moot? ( Please note I am only going by online comments as I dont have access to the ruling)




    Paul has answered in latest post…..I think.

  3. Dontbrattbakkinanger on

    Just because Heidi Poon [Fenian Army!] is in the minority it doesn’t follow that she’s wrong.

  4. Tooting Tim – we will be in the West End House, Kirkstall Road, Leeds. – in case you get stuck.

  5. Awe_Naw_No_Annoni_Oan_Anaw_Noo on

    Those players are now International managers. I wonder if De Boer will start to get pressed by the HMRC just before they meet England ?




  6. Surely this result suits HMRC?


    They had no chance of getting anything from the deceased club, they can now go after ex players and cardigan wearers, who will have money.

  7. So gents



    Burst Hun FC have to pay nothing …good the have nothing



    Whereas a large number of Huns who lorded over us thro the years have to repay HMRC out of their own pockets






    They are clearly guilty of dual contracts



    What’s not to like or am I missing something

  8. HMRC – ” oh, they were loans were they? And the beneficiaries was going to pay them back were they? Ok beneficiaries, time to stump up. Those loans go towards the creditors pot”



    Barry Ferguson, Campbell Ogilvie, Souness, Walter…….” eh? hang on….”

  9. Paul,in the interests of clarification,(that’s a fancy of way saying i’m dumb),are you in agreement that they have,in fact,won the case?,it would certainly seem so,given subsequent reports.

  10. C’mon Spartak – give us a draw.



    We need Barca to field a full-strength team with something to play for in their last game v Benfica in Camp Nou. A bit of insurance just in case we suffer tonight.



    I would prefer CL football after Xmas as opposed to the guarantee of Euro League a Moscow win for Barca would give us.



    A final day showdown means we can take Spartak in Glasgow, perhaps even a draw would see us trough knowing Barca were trying full-tilt against Benfica.



    Of course, pumping Benfica tonight would negate all my apprehension ;)

  11. For a while now, we’ve been trying to educate the huns about EBTs. That they were not illegal if used correctly.


    The problem they had with EBTs was a monetary one that could have, and in effect did, kill them.


    They couldn’t get their heads around the dual contract issue as a secondary issue. They still can’t!


    Today’s findings now make it easier for the SPL to prove the case against them.


    That is, unless the Trust can come up with a story about why it paid out these loans to players at that time.


    What I’d like to know is WHO told the Trust members to give the players the loans, and why that amount.


    There has to be a link between the Trust and the deadclub.




  12. Awe_Naw_No_Annoni_Oan_Anaw_Noo on




    This decisionif not successfully appealedis a nightmare for HMRC and especially George Osbourne hope of increasing revenue. Easier to go after UK registered companiesthan thousands of individuals scattered around the world.



    It is a bigblow for the government andwould appear to me that the majority of judgesin this case ignored the legislationor effectively anulled the emergency legislation that Osbourne brought in in his emergency budget ..thesummer before last.




  13. Didn’t Minty receive £6m in EBT payments??



    If so surely he must be more worried than any other recipient?

  14. SPL will now have to look at non registration of remuneration on a case by case basis. Means that all documentation must be provided by a company in liquidation….. One for the records management experts out there

  15. Lennon n Mc....Mjallby on

    Tooting Tim



    Try the City Vaults and the Lord Clyde,its the same consortium that own them which includes the guy that set the Clyde up as a Celtic bar,he is now based in the Vaults,Sean,both pubs are a ten min walk apart,he will be watching the game in one of them with his pals.

  16. Awe_Naw_No_Annoni_Oan_Anaw_Noo on

    I have done extensive reading on BDO on the net



    Think Duff & Phelps



    BDO will be very familiar to Private eye subscribers also.




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