Which would have been taxable on him. So rather than pay tax. He offsets the interest with the loss commercial income. Either way. Nufc only lose the bet of the comm income and interest. When I used to hear fans say things like “where’s the money gone etc” it used to drive me bonkers he can’t extract the cash without it being visible.
Are you acting for the Club in relation to the HMRC investigation as they are asking the same question....allegedly?
Ha well. If your interested I can explain. The club have provided for an expected future cost, it’s called an accrual to settle the hmrc tax dispute. It’s on the balance sheet and accounted for through the profit and loss account. The liability is provided for as a best guess estimate of what the club expects they will have to pay including interest if the revenue price the club has done wrong. The fact that the club has provided for said accrual means they are not sure if they will win the case or not. That’s Called prudence. There is a realistic possibility that the Revenue will win. The tax and ni losses will be because of tax planning instigated by the clubs accountants at the time. I don’t know what the case is but my best guess is it’s a player rights issue. So rather than pay a player salary which is taxed and ni’d by the player and the club (expensive). The club pays a rights fee which is not (apparently) taxable through paye. The players gets his money tax free. The club save ers national insurance and the only losers are the revenue. Which I might add is basically me and you.
Yes your right. They know it’s tax planning aggressive. But in the tax planning world and provided it’s not tax evasion “shy bairns get nothing”. Tax consultants (I’m a qualified tax consultant by the way) look at legislation (tax law) and find loop holes to exploit. When new legislation is written it quite often contradicts older legislation. So aggressive and very clever tax consultants can sell tax planning schemes (careful as tax schemes have to be disclosed to the revenue - how dare the revenue want to see our devious schemes) to usually already wealthy people to save significant tax. At a very high fee of course. But when these schemes are too aggressive and not in the context of fair play (most schemes are to good to be true right) the the revenue investigate. I’ve seen some dodgy **** in my time honestly. For the record I play within the rules of the law and also I’m not a clever tax planner who likes to get their nose dirty. Tax consultants and solicitors don’t like each other.
Was one of the first jobs I wanted to do after, of course, retiring from being No 9 for NUFC. I’d read that a Tax Lawyer analysed the budget for about 2 to 3 weeks. (Only one budget at the time). Came up with a devious scheme. Sold it for loads of money. Worked for about 6 to 7 weeks each year but was fabulously well off. Didn’t happen as tax law was too difficult and too boring. Mind the Newcastle number 9 hasn’t happened either...yet.
I think I’ve realised that the PL are actually not even equipped to deal with this decision. They are woefully out of their depth, have no experience of this. They are just a glorified marketing department. Dare I say this should be a FA or Gov decision.