Paquis

Nope .... definitely not a 'good guy'. But where his interests and ours coincide ...............

SIR DAVID MURRAY TAKES LEGAL ACTION OVER TAX LEAKS(Issued on behalf of Levy & McRae Solicitors and Notaries Public Professor Peter Watson of Levy & McRae has confirmed that he has been instructed by Sir David Murray to submit a complaint to the Crown Office and Procurator Fiscal Service regarding the publication of information relating to his tax affairs. Professor Watson said: "Sir David regards such information as private and confidential and the publication of such information as unlawful. He has asked that this matter is investigated and that anyone found guilty of breaching the law is the subject of prosecution." Squeaky bum time at HMRC, for certain 'journalists' and bloggers

At least we have an intellect.

You really need to stop making stuff up. There were 111 trusts of which 108 were actively used. 81 were for Rangers players and 27 for Murray Group employees (FTTT decision, para 96). The rest of your post is fiction and not very good fiction either.

I would leave your socks out of this

Great minds think alike

It really isn't very good. And I simply do not believe that HMRC have told him anything beyond that they are considering an appeal. With a possible police investigation into leaks, they are not going to be telling anyone anything right now. Neither do I believe he has spoken to any 'experts'. Otherwise he would have known that a majority decision is not sufficient cause for an appeal. Finally, he makes an error of fact right at the end: "Meanwhile the wider case for legislation on these loans looks even more overwhelming as the rest of us fork out more tax in return for spending cuts." Did nobody tell him that this already happened in the 2011 budget What a clown

If you are referring to Thomson's blog then, yes, I read it. Frankly, I don't think it is very good.

I have removed most of the quote to save space on the board. Oor Alex is a master at cherry picking the bits he likes. And just about all of it comes from the dissenting opinion. Funny how that happens The dissenting opinion certainly provides some essential information that none of us knew. For example on page 102 para 121. 121. The occasion of Rangers winning the UEFA championship led to six sub-trusts being created for Mr Warwick, Mr Camden, Mr Islington, Mr Kensington, Mr Balham, Far be it for me to doubt the eminent Dr. Poon on statements of fact. However, this little faux-pas might lead to the rest of her narrative being treated with less credibility than it might otherwise deserve. How many other 'facts' has she also got wrong? On the question of the appeal, that can only be on a point of law. The fact that this was a majority decision and not a unanimous one is not a point of law. Finally, HMRC have 56 days to appeal. Appeals are usually heard within 12 to 24 months and the decision takes another 6 to 9 months. So we could easily be looking three years down the road. By that time the old club will be dead and buried so no money there. It also begs the question as to what the SFA/SPL will do. They have clearly been waiting for the FTTT verdict. If it is appealed will they also wait for that?

I wonder if the BBC will also be highlighting their own efforts at tax avoidance in the program

It is, however, normal practice for us to complete a sentence with a single full stop rather than three.

Well, if this business ends up in the Court of Session, I know which perspective will carry the most weight.

That is not what the Tribunal found.

The SFA/SPL have two problems. The first is proving that the EBTs and side letters represent dual contracts in the sense of their own rules and regulations. The second is proving that they were not disclosed. The majority verdict suggests that the EBTs were loans. In paragraph 208, they specifically state that they regard the side letter's obligation does not amount to an emolument. There is nothing in the SFA/SPL regulations that require disclosure of loans. There are also a couple of sections in the dissenting opinion that suggests that disclosure did happen although what was disclosed was rather vague. Given that EBTs had been around for over 10 years before the SFA/SPL discovered they had a problem with them suggests that the vagueness of disclosure was not an impediment. There are some exceptions where the Murray Group admits a tax liability. Not all of these concern footballers although a few do. The first is termination payments. However, given the Juninho precedent, it will be difficult for the SFA/SPL to argue that these should be sanctioned. The second concerns guaranteed bonuses and involves just 5 players. Obviously we do not know which players. However, it is not clear that these bonuses were hidden from the SFA/SPL given the points raised in the dissenting opinion and neither is it clear that these bonuses were the subject of a second contract.

You chaps really seem to have some difficulty when it comes to reading comprehension. I was summarising my understanding of Green's position. Personally, I disagree with him. My own view is that the verdict of the FTT will make it very hard for the SPL to prove that the EBTs and associated side-letters were dual contracts in the sense of the SFA/SPL regulations. Unless HMRC appeal and unless that appeal succeeds, I don't see the SPL or SFA being successful.