Jolyon Maugham - On Ebts And Rangers Fc – Part 2

[Old Blue Nose 10]

Jolyon Maugham - On EBTs and Rangers FC – Part 2

For those who read part 1 here is part 2 - The debate that follows is interesting – good read.

http://waitingfortax.com/2015/11/08/on-ebts-and-rangers-fc-part-2/

[writingranger 1,425]

I think that the very fact that there is doubt and argument over the specific use by Rangers' Board of the scheme and that they were paying for tax advice shows they believed they were legal and acting in good faith.

[cushynumber 25,178]

theres a lot of that I am still trying to get my head around. I notice he concentrates on actual tax intricacies rather than "common sense" - so he doesn't take the lazy route. However this bit made perfect sense:

So will there be an appeal?

I don’t want to speculate about the financial position of whoever’s running the litigation. There are other people around who are better informed than me on that subject.

But if there is money to fund it I’m pretty sure there will be an appeal. It would be an odd decision to stop at your first loss, having won twice. That’s especially true where you’ve lost on a ‘new’ point. And it’s especially, especially true where that new point is controversial. I can put my hand on my heart and say that all of the tax professionals I have spoken to about the Decision find it difficult to see how it can be right. They might all be wrong – but that sort of sentiment towards the Decision is absolutely going to encourage rather than discourage an appeal.

[writingranger 1,425]

Yes and clearly all the tax advice the board received suggested this was a legitimate scheme. We don't yet know but the tax liability may be as little as £5m

[Old Blue Nose 10]

For those who are following Jo Maugham this is the final part.

On EBTs and Rangers – Part 3

by Jolyon Maugham

[Shuggy 1,308]

The thing that always confused was whether the receivers BDO can call in the EBT loans made to the players to beef up the creditor pot?

[magic8ball 27,901]

The thing that always confused was whether the receivers BDO can call in the EBT loans made to the players to beef up the creditor pot?[/quote

From memory the loans require repaid after I think 80yr ,so legally I don't think this could stand plus the loans will be due to the trust wether they can be reclaimed from the trust is another thing ]

[Shuggy 1,308]

The thing that always confused was whether the receivers BDO can call in the EBT loans made to the players to beef up the creditor pot?[/quote

From memory the loans require repaid after I think 80yr ,so legally I don't think this could stand plus the loans will be due to the trust wether they can be reclaimed from the trust is another thing ]

80 years!? I suppose it is also interest free?

[magic8ball 27,901]

80 years!? I suppose it is also interest free?

I would assume so,another thing that was in ebt was the club agreed to pick up any future tax liabilities ,

I remember when ebt first came out and the way the schemes worked were reported widely in the media ,and they were valid loopholes in taxation to allow British companies to remain competitive againt foreign companies due to our relatively high tax rates

Funny how the media forget

[theiconicman 2,996]

Just a thought, somewhat completely unrelated, but in effect each player is a creditor to the EBT trust. If they die (which is quite conceivable given 80 years need to pass) the debt must still reside with their estate.

Would this not impact their inheritance? Or at their clauses that nullify the debt on death?