More EBTs in Tribunal
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  1. #11

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    Quote Originally Posted by eek View Post
    Why are you once again making assumptions that are wrong and don't match the facts - this time it took 1 10 second search to find out you are incorrect and wrong....

    from http://www.rossmartin.co.uk/sme-tax-...s-big-ebt-case



    Oh and HMRC know there is no money left to claim from the employer who paid into the scheme. That's not the point of the story here it was pick a winnable case and fight it to generate appropriate case law to then force everything else into....
    i'm incorrect and wrong? maybe you need to control your rage and do a bit more research before making a fool of yourself chasing someone around a forum, as if what you're claiming is true and Rangers paid all the money into the EBTs, then the liquidators of that company have over 20m to distribute to creditors, including HMRC.
    Last edited by FakeHorizon; 26th September 2017 at 16:06.

  2. #12
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    Quote Originally Posted by FakeHorizon View Post
    i'm incorrect and wrong? maybe you need to control your rage and do a bit more research before making a fool of yourself chasing someone around a forum
    Yep - show me documentation that contradicts what I linked to and shows (as you claimed) that the money in Rangers' EBT came from more places than just Rangers Football club....
    merely at clientco for the entertainment

  3. #13
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    Quote Originally Posted by FakeHorizon View Post
    i'm incorrect and wrong? maybe you need to control your rage and do a bit more research before making a fool of yourself chasing someone around a forum, as if what you're claiming is true and Rangers paid all the money into the EBTs, then the liquidators of that company have over 20m to distribute to creditors, including HMRC
    why and how would they have 20m to distribute?
    merely at clientco for the entertainment

  4. #14

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    You actually want to take a random commentary from the internet and publish it as 'fact' on here??

    From the bottom of your article...
    "Case:

    (1) MURRAY GROUP HOLDINGS LTD; (2) MURRAY GROUP MANAGEMENT LTD; (3) THE PREMIER PROPERTY GROUP LTD; (4) GM MINING LTD; and (5) RFC 2012 PLC (in liquidation) (formerly The Rangers Football Club PLC) "

    So it wasn't just Rangers FC, it was Murray Group as well. What role do you think David Murray had at Rangers FC which saw him earn 6m from EBTs alone? I have to say whilst I find your childish behaviour incredibly amusing, all it's doing is deflecting from the adult discussion at hand.
    Last edited by FakeHorizon; 26th September 2017 at 16:07.

  5. #15

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    Quote Originally Posted by eek View Post
    why and how would they have 20m to distribute?
    have you ever heard that saying about how it's best to stay quiet and only let people think you're a fool, rather than keep talking and confirm it? do you also think HMRC wanted the decision they got, that the company is responsible? you don't think they wanted a decision which allowed them to go after scheme users, who are the easier targets?
    Last edited by FakeHorizon; 26th September 2017 at 16:07.

  6. #16
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    Quote Originally Posted by FakeHorizon View Post
    have you ever heard that saying about how it's best to stay quiet and only let people think you're a fool, rather than keep talking and confirm it? do you also think HMRC wanted the decision they got, that the company is responsible? you don't think they wanted a decision which allowed them to go after scheme users, who are the easier targets
    I don't know if HMRC are happy with the final result but the bit they really cared about was the decisions in the initial tribunals that tax should have been paid - and that was the actual purpose of these tribunals were EBT payments subject to income tax or not - final answer yes they are...
    merely at clientco for the entertainment

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    Quote Originally Posted by eek View Post
    I don't know if HMRC are happy with the final result but the bit they really cared about was the decisions in the initial tribunals that tax should have been paid - and that was the actual purpose of these tribunals were EBT payments subject to income tax or not - final answer yes they are...
    and what does any of that have to do with the nonsense you're posting on yet another thread just to get at me.

    and the decisions in the initial tribunals found that tax did not have to be paid, that the sums involved were loans. you're having a nightmare today!
    Last edited by FakeHorizon; 26th September 2017 at 16:07.

  8. #18

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    Quote Originally Posted by FakeHorizon View Post
    and what does any of that have to do with the nonsense you're posting on yet another thread just to get at me.

    and the decisions in the initial tribunals found that tax did not have to be paid, that the sums involved were loans. you're having a nightmare today!
    Not quite.

    The decisions in earlier stages were that the sums were not employment income and as such tax could not be collected via a PAYE assessment (Reg 80 determination).

    In the decisive hearing at the Supreme Court, the Judges held that the amounts paid by Rangers FC were employment income and could be collected via the Reg 80. You should note that the Murray Group companies that were part of the process in earlier stages pulled out before SC and presumably have settled with HMRC - who knows.

    The reports published by the liquidators show that they had substantial sums and the assessments would have been lodged as creditors many years ago. I very much expect HMRC to walk away with the majority of what they want.

    What is potentially more interesting is whether the companies were able to reclaim money from the EBT via a tax indemnity clause and if so, does that mean that the EBT can seek repayment of their loans to pay that indemnity?

    I don't know.

    It might also be interesting to see if the liquidator has grounds to go against those who designed and implemented the scheme. Again, I have no information on that.

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    Quote Originally Posted by eek View Post
    I don't know if HMRC are happy with the final result but the bit they really cared about was the decisions in the initial tribunals that tax should have been paid - and that was the actual purpose of these tribunals were EBT payments subject to income tax or not - final answer yes they are...
    From the long pause in the HMRC webinar last week and the subsequent "the decision was wider than we expected and we're still thinking about it" response, I suspect that HMRC is struggling.

    I suspect you are on the right lines about HMRC initially thinking that a decision that the sums are taxable was what they wanted.

    However they won big but that means probably that the employer is responsible and many of those have disappeared forever, leaving HMRC with a lot of egg on face. I think PAC will be very interested.

  10. #20

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    Quote Originally Posted by webberg View Post
    From the long pause in the HMRC webinar last week and the subsequent "the decision was wider than we expected and we're still thinking about it" response, I suspect that HMRC is struggling.

    I suspect you are on the right lines about HMRC initially thinking that a decision that the sums are taxable was what they wanted.

    However they won big but that means probably that the employer is responsible and many of those have disappeared forever, leaving HMRC with a lot of egg on face. I think PAC will be very interested.
    ... which takes us to the next stage of the battle, 2019, and HMRC's anticipated attempt to pass liability from employer to employee.

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