Tax, rules, Juninho and EBTs


The SPL yesterday released a statement concerning the Employee Benefit Trust payment Celtic made in 2005 to Juninho, in response to what sounded like unfounded allegations made earlier this week.

The league noted, “we have seen reports regarding an EBT in relation to a former player of Celtic FC.  The SPL has investigated the arrangements and documentation in that case and has determined that there is no evidence of any breach of SPL Rules”.

Many good employers have understood the benefit of assisting individual members of staff during times of crisis or personal hardship.  One very practical way of doing this is to lend them money, which happens in businesses up and down the country every day.  When the nature of these transactions involve either a company of sufficient size, a lengthy repayment period, or a high value loan, a formal structure is needed to establish the terms of the transaction, not only for the benefit of employer and employee, but also for the tax authorities – who authorise tax-free payments of this kind.

These tax rules were not established to allow wealthy individuals to escape their social duty.

Not long after Rangers first operated an Employee Benefit Trust Celtic were approached and offered consultancy to establish a similar scheme.  The promised benefits were huge, vast quantities of cash would no longer go to HMRC and would be freed up to spend on new players.

Celtic were not convinced.

Loans would need to be repaid and if not, contractually binding transactions would need to be documented in accordance with SPL and SFA rules, and this very documentation would make them liable for tax.  For Celtic, EBTs could only be used in limited circumstances, would be unable to deliver a significant impact on the business, and would introduce a further layer of professional costs.

“How can these work?” That was the question. How on earth can a club pay millions of pounds into a Trust none of which is contractual? Players, and their agents, like to have things written down. If you write it down and inform the authorities, you’re taxed on it. Celtic were not prepared to enter any written agreement and not declare it to their auditors, HMRC or the football authorities.

What was the cost of this principled stance?

In season 2004-05 former World Cup winner, Juninho, arrived at Celtic from Middlesbrough on a straightforward contract, his only contract with the club, which was correctly registered with the football authorities.  He only lasted eight months before agreeing to terminate his deal.  Celtic made a payment of around £750k into an EBT the player had from before his time at the club.

Celtic informed HMRC of the details of their EBT transaction with Juninho and were told this was regarded as income, not a loan, and that they would need to pay tax.  Celtic then paid tax due on top of the £750k which went to Juninho.  It was a pointless and expensive exercise for Celtic, but they dealt with it honestly and openly.

The club’s understandings of EBTs from five years earlier were confirmed, this was not a way to avoid taxation by filtering part of a player’s income away from PAYE.  Board members of any other club which understood how to make this work were clearly a lot smarter than our guys.  They were also able to buy players and win leagues while our board were hammered daily for their prudent values.

I bet directors at that other club are sounding pretty contrite now, humbled by the emerging news. There will be no self-serving vainglorious rabble rousing.

Far from Celtic being subject to criticism on this matter, scrutiny of their actions will only reveal the stark cost of following the rules when others don’t.

Congratulations to the campaigners who for 23 years sought Justice for the 96.  We all watch the game in a safer environment because of the loss endured by the families bereaved at Hillsborough.  Yesterday’s report condemns the actions of many: some senior police officers, sections of the media, one or two of who should never work in the industry again, and a former MP, whose actions were truly appalling, and who remains a knight of the realm, but those running the game, those responsible for Health and Safety standards, and various governments have a responsibility to bear.

Dangerous crushing inside and outside football grounds was a fact of life in the 1980s, including at the Janefield St entrance to Celtic Park.

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  1. Steinreignedsupreme on

    THE EXILED TIM16:32 on 13 September, 2012



    “Political pressure has been brought to bare/bear, why else would a request from a high court judge have been ignored, or put on the back burner without any explanation.



    “Then my fear is a government bail out.”



    Seriously. You think the Government are going to bail out the Huns?



    No one in London gives a damn about Rangers. They are not as remotely important as their lunatic supporters think they are. You know, the ones that said they would never be liquidated and that HMRC would do a deal with them, and that the SPL couldn’t survive without them … ect, ect, ect…

  2. Thursday, 13 September 2012




    THE fact that Celtic is the ONLY club who would benefit if Rangers are ROBBED of five of their titles should have set alarm bells ringing on the sixth floor inside Hampden. But no it didn’t did it? No it didn’t. This wicked truly evil scandal is the burglary of sportsmanship on a mass scale.



    The Scottish Football Association chief executive, Stewart Regan, along with his counterpart puppet at the Scottish Premier League, Neil Doncaster, should have provided the sort of leadership they are paid to provide to our game. Instead they are in the pocket of Lawwell. Doncaster is jude to Regans punch. Well Rangers have been punched in the face so many time now that I will have no more of it. It has to stop. NOW!



    Unfortunately the old Lion Rampant of Scotland is being led by a pair of donkeys. They are knackered. They are castrated. They should be put out to pasture or put in one of those sanctuary’s you get. But what is happening? They are being used as Lawwell’s attack dogs. Continuing to harass and harry a defenceless and battered Rangers who are still trying to get up from the gutter they kicked them into.



    A pair of braying, snorting and apparently cowardly asthmatic donkeys who don’t look strong enough to give a two- year-old a ride along the sands at Blackpool.



    For instead of ensuring there was not even the merest hint of suspicion that there could be a conflict of interest, by keeping anyone from inside Celtic, or anyone associated with Celtic, at more than arm’s length from the process, Stewart Regan and Neil Doncaster have actually stampeded in the opposite direction. Celtic, alongside deeper, darker, more insidious shadowy forces in the background, are orchestrating all this for political purposes. There are unseen hands at work here. Massaging things like an invisible magical masseur. Many invisible hands make short work!



    Stewart Regan and Neil Doncaster have allowed the whole process of this suspiciously timed witch hunt into the Rangers EBTs – which the SFA and SPL have known about for ten years – to be highjacked by the one club which would benefit from Rangers being robbed of five titles….



    Celtic! Yes Celtic! CELTIC!



    It is an astonishing shambles which many believe verges on collusion and is certainly confusion- a confusing conspiracy to spread confusion!



    Or at least it appears to be Stewart Regan and the Scottish Football Association, along with Neil Doncaster and the Scottish Premier League, wishing confusion on Celtic’s rivals…



    Rangers! Yes Rangers! RANGERS!



    Why else would Stewart Regan not have passed on to Rangers a copy of Lord Nimmo Smith’s report to the SFA about the EBT’s which Rangers say he commissioned and which Rangers insist he has a copy of? This is a witchhunt of Dark Age proportions and Lawell is the Witchfinder General. As I speak to myself they are building the bonfires high into the darkest night of deadly doom!



    Why else would Stewart Regan give every impression that he cosies up to Celtic chief executive Peter Lawwell inside the Hampden Boardroom after Lawwell was parachuted into the powerful Pro Game Board, despite having no previous SFA experience, just after Regan was appointed as chief executive? Lawwell buys the biscuits. I’ve seen the receipts! Marks and Spencers top of the range cream buns! WHat does all this mean? Cream buns? Its a form of cannibalism!



    Why else would SPL chief executive Neil Doncaster appoint Celtic’s lawyers, Harper Macleod, to collect evidence against Rangers? The same company that employed Lawwell’s sister in laws neice over the summer holidays five years ago? If that is not a conflict of interest then I’ll eat my khaki coat!



    Why else would Neil Doncaster then unleash Celtic’s lawyer, Rod McKenzie, as his chosen attack dog to prosecute Rangers?



    Why else would the SPL head honcho Doncaster allow the appearance to develop that Celtic lawyer, Rod McKenzie has either chosen or had an input in the selection of the three-man Scottish Premier League so called Independent Commission?



    It stinks to high heaven as a conspiracy to do Ranger in. They are out to get the one true Protestant club in Scotland. That is what this is all about. Republicanism plain and simple.



    Why have Stewart Regan at the Scottish Football Association and Neil Doncaster at the Scottish Premier League done all these things? I believe they are not actually English. They are Irish Republican reptiles from another star system putting on an accent. I have over heard them speaking with thick Oirish accents when I was hiding in one of the cupboards at Hampden. They used advanced technology to contact their leader on Ursa Major. SO there you have it: O’Doncaster and O’Regan are all Irish Republicans reptiles from the star system Ursa Major.



    Celtic are the ONLY club which would benefit from Rangers being SAVAGELY MUGGED – -like little innocent children having their lucky bag taken off them by an evil man named PETER- of five of their titles, Rangers?



    For neither Peter Lawwell’s SFA pal Stewart Regan or Lawwell’s SPL chum, Neil Doncaster have presented themselves for scrutiny and questionioning over this whole sad, sorry, sordid, sick, evil, disgusting affair.






    Did I call Stewart Regan and Neil Doncaster knackered donkeys?



    Belay that!



    Stewart Regan and Neil Doncaster are Irish republican alien reptilan asses.

  3. Big Nan…edited excerpts;


    The reality of the situation is that Sir David Murray, who was intimately involved in the architecture of these efforts……


    Finally, I would hope that the panel which has been charged with investigating Rangers’ activities will draw a large circle around a universe of relevant reference points…..

  4. TET – watch your language. Paul doesn’t like stuff like that. You might bet black-balled. ;-)

  5. Steinreignedsupreme



    The SNP will bail them out for the reasons I stated above.



    I also reckon that ibrox will be bought and put into some sort of government trust.



    The sfa are directly funded by the scottish government, do you think that the english fa would get away with what their scottish counterparts are doing without the government getting involved.



    The sfa are the huns.



    The only real hope I have is that the huns bring down the sfa, and we are released from the hell.

  6. Even knowing how terrible the Scottish sporting press are, it is genuinely astonishing that Leggat was ever employed by a major newspaper.



    His rantings are insane, illogical, paranoid.



    And he is a hero on FF…



    … is it any wonder their club collapsed?

  7. TET,



    Government in London won’t touch Huns with a bargepole.



    Government in Edinburgh might – but they would be playing with fire and I suspect any help would be deep, deep, undercover stuff.

  8. Neil canamalar Lennon hunskelper extrordinaire on



    D&P were forced into the job early, HMRC did not contest their appointment, IMO this was to give them enough rope.





  9. Neil canamalar Lennon hunskelper extrordinaire


    17:20 on


    D&P were forced into the job early, HMRC did not contest their appointment, IMO this was to give them enough rope.




    Charlie Green bought the rope along with certain other assets, I believe.

  10. ‘Celtic, alongside deeper, darker, more insidious shadowy forces in the background, are orchestrating all this for political purposes’



    Even better than I had hoped then.


    Anyone care to speculate me who these insidious forces could be?


    I’d go for the unpaid newsagents and crystal decanter engravers of Old Glasgee town, hell bent on revenge, myself

  11. ItaliaBhoy



    I, all my Celtic supporting life have been classed as paranoid, I like most Celtic supporters knew what was going on behind the scenes.



    Now that paranoia has been shown to be founded.



    I for my sins, know a fair bit about the masonic powers who inhabit scotland, and I believe that their influence will prevail.



    Call me paranoid, I’m used to it.








    HMRC did contest their appointment, the judge over rulled on the condition they were appointed immediatly, and not at CW’s behest.

  12. Steinreignedsupreme on

    THE EXILED TIM 17:13 on 13 September, 2012



    “The SNP will bail them out for the reasons I stated above.



    “I also reckon that ibrox will be bought and put into some sort of government trust.”



    No one cares about them enough to do that. There were about 10 Huns outside Ibrox the day they were liquidated. You overestimate their importance.



    The SNP do not have any influence over the future of the Huns. None at all.

  13. Tomtheleedstim



    Subtler than his first effort, but that’s not saying much.



    Martin Short called the followers of TGAOTU the mafia of the mediocre!

  14. Steinreignedsupreme



    The people who control the SNP’s strings do though.



    You believe one thing, I believe another.



    Best thing is to wait see what transpires.



    I honestly hope I am wrong.

  15. Steinreignedsupreme on

    O.G.Rafferty 17:27 on 13 September, 2012



    “Even better than I had hoped then.



    “Anyone care to speculate me who these insidious forces could be?”



    The Vatican, the Mafia, the Irish Govenment, the Real IRA and the remaining members of the Kennedy Clan.

  16. thebhoywithmcgraininhisside on

    “It stinks to high heaven as a conspiracy to do Ranger in. They are out to get the one true Protestant club in Scotland. That is what this is all about. Republicanism plain and simple.”



    2 questions:



    When did they change the meaning of republicanism? I must have missed that memo.


    Is barack now a celtic fan?

  17. I asked in Easons in O’Connell St. yesterday if they stocked downfall.



    “No”, was the answer and the girl said that I wasn’t the first to enquire about it.




    Don’t forget the Irish market, Phil.





    TET will not be far out in his version of Scotia’s Scandal.

  18. Steinreignedsupreme, 17:34


    Keeps them off the streets I suppose. As they’re busy on this project I wonder if they have had to put out to tender the Undermining of Loyal Ulster? I think we should be told

  19. Steinreignedsupreme on

    THE EXILED TIM 17:34 on 13 September, 2012



    My point is that if they had such influential people on their side the Huns would not have been liquidated.



    And no matter what happens they will not riot on the streets. Seriously, this is Vanguard Bears territory you are on.



    And as you say … we will see.




  20. Neil canamalar Lennon hunskelper extrordinaire on



    I think you’ll find I am spot on.


    our hero whyte wanted to delay administration for as long as possible, the only thing hmrc insisted on was the timing. They offered to put ther own adminstrators in and could have insisted on this but did not, remember they were the biggest creditors. Their sole aim was to have an administrator appointed asap to scupper whytes plans.


    Administration is court appointed therefore answers to the law, if any irregularities are ignored by anyone up the food chain including the judge, they are in contempt of the regulations and law. Judges can be investigate too.

  21. Why else would SPL chief executive Neil Doncaster appoint Celtic’s lawyers, Harper Macleod, to collect evidence against Rangers? The same company that employed Lawwell’s sister in laws neice over the summer holidays five years ago? If that is not a conflict of interest then I’ll eat my khaki coat!



    PMSL Brilliant!!!

  22. Paul67



    This will be the MP you allude to Irvine Patrick.



    Patnick was one of the sources for The Sun newspaper’s notorious coverage of the Hillsborough disaster in April 1989. In September 2012, the publication of the report by the independent panel investigating the disaster confirmed that “the source for these despicable untruths was a Sheffield news agency reporting conversations with South Yorkshire Police and Irvine Patnick, the then MP for Sheffield Hallam.”[7] Earlier, Sun editor Kelvin Mackenzie had said of his coverage: “It was a fundamental mistake. The mistake was I believed what an MP said.”[8] The Daily Express also carried the story, under the headline “Police Accuse Drunken Fans” and giving Patnick’s views, saying he had told Margaret Thatcher, whilst escorting her on a tour of the grounds after the tragedy, of the “mayhem caused by drunks” and that policemen had told him that they were “hampered, harassed, punched and kicked”.[9]

  23. I have a good mate in England (where I lived for many a year) and he thinks that I say what I say about Rangers simply because I am a Celtic supporter. So, what I need, is to be armed with FACTS about THEM. eg They did not sign a Catholic for X years.


    What I need from you god CQNers, is more of the same. I also need to be able to support any facts I am given. On that note, someone posted Smith`s record as Scotland manager. I was doubted when I mentioned it to some guys. Anyone got those figures?




  24. Following the disclosure of Patnick’s role in creating what Prime Minister David Cameron called an “unjust and untrue narrative that sought to blame the fans” Labour MP John Mann wrote to Cameron asking that Patnick be stripped of his knighthood for his “shameful and disgusting behaviour





  25. Steinreignedsupreme



    Liquidation is just a process that has to be adhered to, it could not be stopped.



    The aftermath of the event is what bothers me.








    I think we are both right.


    HMRC wanted BDO, the judge insisted that an admin co was appointed asap, HMRC accepted the judges decision to appoint D and P.







    I hope I am so far off the mark.

  26. Steinreignedsupreme on

    O.G.Rafferty 17:38 on 13 September, 2012



    Anything is possible in the whacky world of Legless and his ilk.

  27. Right children, today we are going to discuss the difference between lending and instituional deception



    On a happy note – I’ve just installed (pluggedin a usb thingy in) a latop cooler, oh happy days !

  28. Neil canamalar Lennon hunskelper extrordinaire on



    hmrc needed to have an administer available to make the demand, they were simply there to force the issue.


    As I said IMO D&P are also being watched very closely, hence my give them enough rope comment :o)


    Remember conflict of interest will have severe consequences which may provide substantial funds for the creditors :o)

  29. Steinreignedsupreme on

    THE EXILED TIM 17:48 on 13 September, 2012



    “Liquidation is just a process that has to be adhered to, it could not be stopped.



    “The aftermath of the event is what bothers me.”



    Liquidation could easily have been stopped. If the SNP are willing to use public money to help them at all – paying the tax bill and preserving the club’s history would have been the time to do it.



    What happens next? HMRC will have a field day. That’s when the fun really starts.