RANGERRAB

The fact remains that when Rangers entered administration on 14th Feb 2012 the debt was £55m of which £21m was owed to HMRC who had deliberately allowed Whyte to go 6 months without paying Tax/NI. 

This meant that HMRC were owed more than 25 percent of the total meaning they could block a CVA which they did.

The BTC hadn’t been decided at the time of administration.  It had been appealed & the FTTT didn’t report back til Nov 2012

First of a few to go I think....

Man Utd and Arsenal must be thinking likewise. Everton too maybe

I’d always thought HMRC expected to lose the BTC but they won it (in the end).

Now we’re seeing oldco liquidators BDO trying  to reduce the amount owed and are questioning much of HMRC’s conduct throughout the BTC

I suspect they’ll also be asking why Whyte was allowed to avoid paying income tax/NI for almost 6 months 

11 hours ago, Big Jaws said:

Let me be as clear as I possibly can. I'm not an accountant, I don't have any of the exact figures in front of me nor the links to articles/details of those figures either, I am merely basing my assumptions on what I have memory of and my own knowledge of certain tax vehicles. 

 

We know that there were 72 EBT's that held a total estimated to be £48mil. We believe that HMRC levied a bill of £24mil that MIH/RFC disputed and as a result HMRC then imposed fines and penalties to the sum of £94mil. The reasons and legality of these penalties were and indeed still are under dispute. We've also been told that Rangers, by all and sundry, were a test case and were being used to set a precedent.

 

First of all working backwards Rangers were NOT a test case as there had been a prior case also involving Arsenal, whom also crop up again after the fact, which would be considered THE precedent. MIH/RFC Murray were correct to dispute the £24mil bill as in situations where Trusts are established there are rules to govern this. Of course this has been updated since these events and also now include possible income tax rules.

 

The rules at the time which haven't changed and from experience; 

 

Trust containing dividend < £1k are taxed at 7.5% on the first £1k and thereafter taxed at 28%.

Trust containing dividend > £1k are taxed at 38.1% on the first £1k and thereafter taxed at 45%.

 

At no point in any of the subsequent calculations does the tax due ever reach 50% or above. Therefore the 50% figure as you can see is incorrect in ALL cases of dividend in trust even after the change. If we can accept that these Employment Benefit Trust vehicles were, at the time of operation, not subject to income tax then it follows that up until April 2011 they could be recovered/transferred at their previous tax rates although there was a degree of uncertainty, with regards to that, at that time.

 

This degree of uncertainty is what I believe Murray was partly disputing remember that what I am saying is valid with regards to the date where the HMRC claim is established circa 2009-11. The uncertainly aspect, as I remember, was whether or not these new rules would be retrospectively applied. Now Murray could never be accused of altruism but he is right to dispute the HMRC claim a) to allow trustees and employees to make arrangements for transfer, and b) at the time EBTs weren't subject to income tax, not until the SC ruling 2017, and even under these new rules income tax/company tax is only due when funds are 'earmarked' i.e set for withdrawal/transfer*.

 

Now I stick to my previous assertion that Murray had some idea that income tax rules might be retrospectively applied and that he was attempting to clear the debit, at the lower rate, circumventing these probable new tax rules quickly before legislation had been put in place. He NEVER refused to pay HMRC, in fact he offered £9mil plus £10mil over a number of years which IMO is much closer to the correct liability than HMRC's £24mil claim, therefore their step of applying fines and penalties was NOT only inaccurate but was also UNPRECEDENTED!

 

The argument, we [rangers supporters] have always maintained skulduggery, playing out before our very eyes is, not that the HMRC assertion that income tax was due re: the SC case, but that the outlandish figure of £94mil was a gross misrepresentation of the debit Oldco owed on the part of HMRC and that claim effectively hamstrung Oldco as toxic is not only correct but it is also an absolutely unprecedented tragedy of an overarching government body that requires nothing less than a full public enquiry. 

 

* I'm not sure if transferring 'earmarked' funds is subject to income tax/company tax as I haven't looked at them since the rules were amended.

As well as the BTC , doesn’t the £94m include the wee tax case & Whyte’s   non-payment of income tax /NI?

If possible, we should be doing everything we can to persuade Morelos to sign a new long term deal. And it will cost us.

The harsh reality is that it will cost a fortune to replace Morelos with a player of his ability. The £1m we paid for him was THE all time bargain 

As I see things:-

There were 72 EBT’s with a total value of £48m between 2001-09

HMRC sent a tax demand for £24m which was appealed. Then HMRC added a £50m penalty.

seems to me it is this £50m penalty that Oldco liquidators BDO are now questioning.

if they’re successful then it surely means HMRC wouldn’t have been able to block the CVA. 

2 minutes ago, 26th of foot said:

Reading the above, it seems unprofessional. There's a personal/collective edge?

 

HMRC did not miscalculate the original tax bill, the miscalculation came in the draconian and aggressive penalties triggered by EBTs.

 

EBTs were legal.

 

Thus, no miscalculation of figures on original tax owed; however, massive miscalculation on the law - miscalculate ANYTHING???????? 

What was original tax owed on £48m sum total of EBT’s?

And who was liable, oldco ? Players ? Both?

Looks to me we’re entering a crucial stage of oldco liquidation process regards HMRC.

The total value of Rangers EBT’s was £48m. How much tax was due to be paid by oldco on this amount following the court verdict?

For the past few years we’ve had all sorts of figures quoted by slabbering yahoo journalists. Most of these figures included penalties which I understand can only be applied for ‘deliberate behaviour ‘

I suspect the real figure will be around half of the £48m. And HMRC won’t have miscalculated 

I highly doubt it was just one person who was responsible for all of this within HMRC.

Ive always believed that there was a high level yahoo mission both within HMRC and LBG with the aim of financially  destroying  Rangers.

We can only hope today’s news will lead to some sort of internal investigation within HMRC to allow us to get to the truth of what really went on.

The question now needs to be asked whether individuals within HMRC deliberately got the tax amount wrong for oldco. And also if there were outside influences at work.

I’m no accountant or tax expert but I simply do not believe this was an unfortunate error

Squeaky bum time in the EastEnd...

3 hours ago, pete said:

 Mr John Reid springs to mind in all of this.

And others too maybe?

The story has always been out there who was behind all of this. 

James MaClean will be more remembered for refusing to wear a poppy on his shirt than he will be remembered as a footballer in years to come. 

Why does this piece of pond life always need to be given publicity every  Remembrance Sunday ?

Ignore him ??????

We need another goal before we can think about getting all 3 points

1 hour ago, craig said:

I actually think Gerrard will start with Defoe in this one.  Morelos has played so much this season already And needs to be kept fresh.

 

having Morelos on the bench for last half hour if needed is fine.

 

I also think that’s partly why Gerrard has went for the throat recently by playing Defoe and Morelos together when games are done - in the event we need a goal in last half hour and can have them both on at same time.

Why would SG want to start with Defoe???

It’s a must win game. Morelos is the best striker we’ve had since McCoist (not forgetting Negri’s 6 months) .

Still buzzin’ since I got home last night. The Morelos goal has to be one of THE all time great European goals. 

Looking at the table still think we’ll need another win from last two games to go through asI can see Porto winning their two games.

Two failed managerial appointments haven’t helped our financial situation either since 2015.

MW I can sympathise with as he looked sound to begin with but Pedro was never going to work 

Great performance and delighted to be in the final. Morelos is just getting better  & better but we need to be realistic and understand he will eventually leave. I hope our new DoF is identifying replacements 

As long as it’s only one year contracts then no problem 

4 hours ago, the gunslinger said:

Some amount of cash put in by king etc

Yes but that cannot be expected to continue long term.

The reality is since the new board arrived in 2015 we have had two failed managerial appointments which continue to cost us.

However we have turned a corner & things are improving. And theDoF role is crucial.

At least we now have players with saleable value whom we can sell to offset losses. We will lose Morelos & others for fees well in excess to what we paid. How they’re replaced is where the DoF kicks in.

The harsh reality is that for as long as Rangers are in the SPFL we’ll need to operate the model operated by the likes of Ajax and dare I say the yahoos. Buy low sell high.

As I said earlier we’ve turned a corner albeit belatedly. But now the road ahead looks much brighter.

Excellent performance & result tonight. Just hope the Barasic injury isn’t serious 

4 minutes ago, Waltersgotstyle said:

I have said it for months - the Scottish national team should be built around Jack. He has been excellent for over a year now. 

Maybe when Steve Clarke gets better he’ll do that ...??

Maybe chick’s looking for a pay rise at PQ ???

Does anyone take him seriously? ???