Reply to: Murray Group (Rangers) tax case - decision today?

[StrengthInNumbers]

2017 same time we should have decision on first contract mass marketed EBT scheme from FTT. Let's hope tide on EBT and ToAA starts turning opposite to HMRC view.

[Not Losing Any Sleep]

Just so you know...

BDO allowed to appeal Rangers tax case to Supreme Court

Rangers ‘big tax case' rolls on | AccountingWEB

Possible hearing date of Spring 2017 and I guess a judgement by late summer 2017.

[DotasScandal]

It's on...

Just so you know...

BDO allowed to appeal Rangers tax case to Supreme Court

[DcoC]

As expected BDO submit appeal

BDO seek to appeal Rangers tax case decision over use of EBTs - BBC News

Tip - if a celtc fan has an opinion on Rangers, always assume the opposite is true. You'll be right more often than you are wrong

[TestMangler]

So Celtic used an EBT scheme for Juninho? Minestrone - pot calling the kettle black then?

Far be it from me to defend Minestrone, cause he's a tosser, but Celtic only used an EBT scheme for Juninho and have already paid off any deemed tax that anyone could claim wasn't paid, so no.

[Fred Bloggs]

Wow, googling INOH's office address is eye opening. Thanks for the hint.

[webberg]

Hi Graham,

I read this summary about the Rangers case from an email received by a company calling themselves INOH:

Was it actually a win for HMRC?

In what has turned into a political case in which HMRC needed to be seen to win, they may have won the battle, only to have lost the war. There were a number of rulings made that were actually a huge blow to HMRC in favour of previous EBT users:

Contributions are tax deductible for the employer.
Neither employer nor employee is to be taxed on trust investment returns.
The movement of funds from main trust to sub-trusts is not an event giving rise to income tax liability on the employee.
The payment of cash funds out of the trust (even to the employee) is not an event giving rise to income tax liability on the employee.
Loans to the employee are not taxable as the employee’s income.
Loans to the employee are deductible against his IHT estate.

Are these conclusions valid?

Hello, I've moved this to a different thread.

[webberg]

Hmmm, it seems INOH are scheme operators.

It is. The virtual office address is also tainted in many internet searches.

Make no mistake here.

HMG, via HMRC is involved in a well funded and determined campaign to force many contractors to pay a tax rate that is closer that seen with employees. We have seen changes to dividend taxation, travel and subsistence rules are likely to have changes announced this week (perhaps effective next April) and IR35 is a due a "revision" perhaps April 17 at the latest.

ALL and ANY arrangement that says that very high take home pay rates seen in the past are possible WILL DEFINITELY BE CHALLENGED.

A QC opinion is NO DEFENCE. A DOTAS number is NOT an HMRC approval. Being "complaint" is NOT any guarantee of success and is a largely meaningless word in this context.

If you are tempted by such schemes ask yourself why you need complicated arrangements to receive remuneration. If the answer is that you don't, the WALK AWAY.

The ONLY time you should consider aggressive schemes is if you see a letter from HMRC saying that the arrangements work, AND includes a full description of the arrangement. I've been doing this job 40 years and have NEVER seen one.

Ask for that letter. If you don't get one WALK AWAY.

[Fred Bloggs]

Hmmm, it seems INOH are scheme operators.

[pimpernell]

I didn't think I was "attacking" you. If you feel that way, then my apologies.

I'm also not doubting your knowledge of the case. Whilst we may disagree as to the relative importance of certain pieces of evidence or dicta, I'm not suggesting that your view is incorrect.

Perhaps where we differ is that I've spent a lot of time looking at other contractor arrangements and I'm far from certain that the reasoning in Murray can be applied directly or indirectly to those arrangements. I'm not alone in that view and have posted links to others.

I freely acknowledge that the decision has split the tax profession and there are some who have the opposite view. Time will tell who is more correct.

This thread was started to discuss the application of the Murray decision to those other arrangements. I doubt that any of the managers/players who used the scheme discussed in the case are regular visitors here and as such I'm more interested in how the learning from the case is going to be applied. I think most readers of this thread are of the same mind.

Whilst I'm sure that many Scottish football fans have an interest in the case for perhaps non tax reasons (and I confess to being surprised at the strength of feeling) and are interested in the "what happens next" questions, with respect, this thread is not about that and hence I have asked (politely) for a separation.

Hi Graham,

I read this summary about the Rangers case from an email received by a company calling themselves INOH:

Was it actually a win for HMRC?

In what has turned into a political case in which HMRC needed to be seen to win, they may have won the battle, only to have lost the war. There were a number of rulings made that were actually a huge blow to HMRC in favour of previous EBT users:

Contributions are tax deductible for the employer.
Neither employer nor employee is to be taxed on trust investment returns.
The movement of funds from main trust to sub-trusts is not an event giving rise to income tax liability on the employee.
The payment of cash funds out of the trust (even to the employee) is not an event giving rise to income tax liability on the employee.
Loans to the employee are not taxable as the employee’s income.
Loans to the employee are deductible against his IHT estate.

Are these conclusions valid?

[jbryce]

Be my guest

[minestrone]

Hell that's your last Post....over to General....

Be my guest

[jbryce]

OK, very last post, cojak has pretty tight rules on professional, I respect that, those rules don't apply ( as much ) on general and I am certainly not know for any type of solace of comfort in that forum. If you want to take the discussion there then start a thread, don't hide behind a 'mod request to move a thread'.

Not really - it's just a bit dull. You must be the only Celtic fan (in England??) who really gives much of a tulip about Rangers. Aren't you all too busy running away with the Scottish Premiership against errrr zero opposition?
Hell that's your last Post....over to General....

[njwilli3]

So Celtic used an EBT scheme for Juninho? Minestrone - pot calling the kettle black then?

[regron]

And this one....
http://www.telegraph.co.uk/sport/foo...eme-Court.html