HMRC Appeal Statement (In response to that of RIFC PLC)

Blogger Paul McConville commented:-


“Many football fans and legal commentators were surprised by the First Tier Tax Tribunal verdict last November and will not be disappointed that HMRC have now launched an appeal against their judgment.

“The ruling of the First Tier Tax Tribunal does not affect the operations and the financial position of this blog as it stands today and the appeal will have no effect on us as this is an historic case for The Rangers Football Club plc (‘oldco’).

“As HMRC stated last June when they decided to vote against the proposed ‘oldco’ CVA, no tax liabilities relating to ‘oldco’ would transfer across to this blog. HMRC would undoubtedly also reaffirm this position to my tax adviser, Deloitte Del Boy.

“What the appeal does do, however, is cast a cloud of uncertainty and confusion over a situation that has already been ruled on and has taken a number of years to investigate. It means that I will continue to have to write blog posts regarding Rangers and the intricacies of EBTs.

“Some might ask why HMRC are pursuing the matter further when the original EBT enquiry took years to reach a conclusion. Such people have no understanding of the issues, and the fact that oldco is in liquidation does not mean that the appeal is a waste of funds. After all, the liquidator might succeed in ingathering funds, for example by a “gratuitous alienation” case, and thus HMRC could receive a bigger share of what is recovered.

“In any event the appeal will, I imagine, address the Ramsay principles and the issue of “form over substance” or “substance over form”, giving guidance to tax advisers and Revenue officials across the country in the application of the principles.

“And in any event the appeal relates to MIH, and not exclusively to EBTs created in oldco.

“I intend to write in the strongest possible terms to Mr Green pointing out the futility of his writing to HMRC pointing out the futility of such an appeal.

”I may also suggest to Mr Green that winding up (no pun intended) HMRC might not always be the most prudent activity in which to engage. After all, HMRC has many varied and extensive powers of investigation and enquiry, and are assiduous at finding liabilities even where the taxpayer might genuinely believe there to be none.”

Hector Tax


My statement above is in no way intended to reflect the terms of Mr Green’s “Letter from Doha” which is reproduced below.

It does strike me as odd however that Mr Green is so exercised by a matter which even he admits is nothing to do with any of the companies with which he is involved.

Posted by Paul McConville


NB – The official Rangers statement is below:-

RANGERS Chief Executive Charles Green commented: “All Rangers fans welcomed the First Tier Tax Tribunal verdict last November and will be disappointed that HMRC have now launched an appeal against their judgment.

“The ruling of the First Tier Tax Tribunal does not affect the operations and the financial position of the Club as it stands today and the appeal will have no affect on us as this is an historic case for The Rangers Football Club plc (‘oldco’).

“As HMRC stated last June when they decided to vote against the proposed ‘oldco’ CVA, no tax liabilities relating to ‘oldco’ would transfer across to the new company. HMRC have also reaffirmed this position to the Club’s tax advisers, Deloitte.

“What the appeal does do, however, is cast a cloud of uncertainty and confusion over a situation that has already been ruled on and has taken a number of years to investigate.

“There is no money to be gained by HMRC as the old company has been liquidated so you have to ask why they are pursuing the matter further when the original EBT enquiry took years to reach a conclusion?

“I have written in the strongest possible terms to HMRC pointing out the futility of such an appeal.”


Artist's impression of Charles Green receiving news of the HMRC appeal

Artist’s impression of Charles Green receiving news of the HMRC appeal



Filed under Alleged Humour, Charles Green, HMRC v Rangers, Rangers

61 responses to “HMRC Appeal Statement (In response to that of RIFC PLC)

  1. felpan

    It’s Mr Greens job to cut off Allys ear and send the letter, Mr whyte’s job was to create a decoy, Mr Purple will take off with the money and they will all meet up at Mr Red’s, And here I am stuck in the middle with you!

  2. “It does strike me as odd however that Mr Green is so exercised by a matter which even he admits is nothing to do with any of the companies with which he is involved.”

    …maybe he’s obsessed?


  3. Derp

    What’s that coming over the hill
    Is it a Hector. Is it a Hector.

  4. Geddy Lee.

    It does seem bizarre that Green can’t keep his trap shut.

    As he has shown with various , Ill advised comments, he’s not exactly what you would call bright.

    Even the most Knuckle -dragging of sevcovians MUST know why Hector continues to persue this case. Clearly, Green is appealling to the clueless among his share holders with this latest, nonsensical, irrelevant guff.

    His new club have yet to cross swords with Hectors boys, so why is he rubbing them up the wrong way?

    Sadly, while the Scottish media rush to faithfully reproduce each and every Green rant, we will just have to put up with more moronic comments from this clown of a man.

  5. Tecumseh

    Waaaahahahaha . . . . .

    . . . .cont in the Supreme Court . . . .

    Waaaahahahaha . . . .

  6. Ron

    A bit off topic, hope you don’t mind, Paul, I couldn’t resist posting this. It’s meant as a humorous post – not meant to offend anyone !

    I bought a book yesterday “Simon Schama, A history of Britain Vol 3”, The page before the Preface has the following quote from George Orwells’ book “England Your England”.

    I’m sure the wits among you (on both sides !) will have fun replacing certain words dependent on your pesuasion.

    George Orwell’s Original text :

    ” The country houses will be turned into holiday camps, the Eton and Harrow match will be forgotten, but England will still be England, an everlasting animal stretching into the future and the past and, like all living things, having the power to change out of recognition and yet remain the same…”

    • ecojon


      Quite funny although I have to say the analogy might fall down on whether Rangers remained ‘alive’ however I will leave that esoteric discussion to others 🙂

    • If any club can apply Orwell’s sentiments as described in the quote, then they (all clubs) can lay claim to being eternal, I suppose – or at least they can going by the context Orwell meant in this case.

      I dont think theres much to add to the debate on same/new club at the moment, but this might be something. It would involve one taking a view on the nature of change, and whether its an upheaval event, or a process, and where is the reliable narrative in it all.
      Any other relevant literary references anyone?

      • bfb

        Did Orwell not write a book called “Down and out in Paris and Govan”? follwed on from his book about Barca “Homage to Catalonia”. There is of course his magical “Road to Wigan Pier” about a football club coming from non league to premiership status.

        Perhaps my memories of those books are faulty and if so I apologise.

        There was also the line in “it aint half hot mum” where the Windsor Davis character catches the resident intellectualist reading Joyce and demands to know why he is reading a book called “Useless” but that is another story altogether and any allegorical reading of “Useless” to refer to the internal monologue of Yorkshiremen is wholly mischievous.

        • ecojon


          In general I have no problem with ‘the internal monologue of Yorkshiremen’ but I do with the continual externalising of one who won’t shut-up.

        • ‘Never, in the field of the footy conflict, has so much been owed by so few to so many.’
          – Churchill (not the nodding dog one off the telly, the other one).

          ‘I kick, therefore I am (the same club).’
          – Rene Descartes (not Rene from Allo’ Allo’, the other one)

          ‘Let every national association know… that we shall pay any price, unburden any bear of his cash, meet any unnamed investor, boycott any other club, oppose any rule, to assure the survival and the success of a club.’
          – John Fitzgerald Kennedy assassination address (sorry … I meant ‘inauguration’)

          ‘And so, my fellow Spivs: ask not what you can do for your struggling club – ask what dosh your struggling club can make for you.’
          – Chas Fitzgerald Verdi

          ‘Can we fix it? No we can’t!’
          – Bob the Administrator

          The club who longed for SPL return, beholds with pain,
          The tempting successive promotions were too high to gain;
          Grieved in his heart he forced a careless smile,
          And cried ,‘They’re pish anyhow and hardly worth my while.
          – The fox and the Grapes, or Le Renard et les Raisins, or M. Verde et Le Football Ecossais

          ‘History repeats itself, first as tragedy, second as farce.’
          – Marx (Karl, not Groucho)

          ‘Bears of the world unite, you have nothing to lose but your dosh!’
          – Marx (Karl again, not Chico)

          ‘Institutional investor capital is dead labour, which, vampire-like, lives only by sucking living labour, and lives the more, the more labour it sucks.’
          – Marx (Karl again, not Harpo)

          ‘Die, my dear? Why that’s the last thing I’d do!’
          – Marx (Groucho this time)

      • dan

        plus ça change plus c’est la meme chose. (the more things change the more they stay the same) Jean Baptiste Alphonse Karr ‘Les Guepes’ (The Wasps) 1894.

        To which I say ‘Fuck off Jean Baptiste. I know one thing that hasn’t stayed the same. So there!’

      • Budweiser


        ‘God, give us grace to accept with serenity the things that cannot be changed, courage to change the things which should be changed, and the wisdom to distinguish one from the other.
        Reinhold Niebuhr.

        • bfb

          “The tendency to claim God as an ally for our partisan value and ends is the source of all religious fanaticism. ”

          Reinhold Niebuhr again although I am not a great fan of his, if I recall correctly he went from being a man of the people to being an american exceptionalism apologist.

          What I would recommend heartily is the work of Peter Maurin, the intellectual heart of the Catholic Worker Movement. One of his Easy Essays seems perfectly to fit the Scottish Football situation find these and his other views at

          Big Shots And Little Shots

          1. When the big shots
          become bigger shots
          then the little shots
          become littler shots.

          2. And when the little shots
          become littler shots
          because the big shots
          become bigger shots
          then the little shots
          get mad at the big shots.

          3. And when the little shots
          get mad at the big shots
          because the big shots
          by becomming bigger shots
          make the little shots
          littler shots
          they shoot the big shots
          full of little shots.

          4. But by shooting the big shots
          full of little shots
          the little shots
          do not become big shots,
          they make everything all shot.

  7. dave

    Is it not the case that because Rangers’ SFA membership was transferred (and not a new membership) that the recipients of the transferred membership also inherit some of the liabilities of the previous holders?

    That was my understanding anyway.

    • tykebhoy

      If you are talking debt liabilities then some of this was covered in the 5 way agreement. It is believed though that this only covers footballing debts and the scope of those isn’t even clear as almost nobody knows what was in that agreement. It may cover some other debts or it may exclude some football debts e.g. amounts outstanding to foreign clubs

      Consequence\Punishment liabilities are anybody’s guess.

      • @tykeboy

        According to one mischievous commenter on a previous blog, Peter Lawwell knows what’s in it, as he (allegedly) was the architect* of the whole thing.

        *pls note not the Grand Architect, that’s someone else entirely (or is it?..)

    • Vega

      Have you been listening to Gordon Smith on Sportsound, 5/2/13?

      Obviously with all those facts flying around someone on the sports desk though it was time to reintroduce some misunderstandings about the The Rangers affair. Enter Neil Doncaster with his “effective relegation to Division 3” pish and Gordon with “That’s what I heard Greame, you should listen”.

      On the plus side things are looking up in the smoke production and mirror manufacturing industries.

  8. Ron


    Very true – but that’s only if you replace “England” with Rangers. You could replace it with “Celtic”. Cheers.

    • ecojon


      I would not argue with that and have posted on here a number of times about the utter confusion caused by the various rule books and differing interpretations of what the term ‘club’ actully means to begin with before we even move on to any ‘continuing’ concept or otherwise.

  9. JimBhoy

    @Dave it is a new membership HMRC have stated that no financial liabilities will be with the new club (business) with the No vote to CVA…. The SFA have managed to work some financial issues into the equation in my opinion wrongly and illegally. The club can and wll claim they are the same rangers forever there is no proving for or against this, the business is a different entiti(es) in the eyes of the law… I could go change my name tomorrow to charles green but still claim to be the same JimBhoy.

    • ecojon


      Ah but money owed by old JimBhoy would still be owed by the ‘new’ JimBhoy in his Chuckles persona.

      But would you inherit the liabilities of the old chuckles – for both your JimBhoy sakes – I hope not 🙂

    • But … I owned shares in JimBhoy, so are they all worthless now?

      …oh, I see – its just a name change. Thats OK then, my shares are still worth something.

  10. mcfc

    Mr Green is clearly worried that his LNS smoke screen is drifting away.

    He can no longer claim that he / oldco / club “won” the FTT case. Assuming LNS finds oldco guilty as charged, by the time the appeal to the SFA is over, he / oldco / club may have “lost” the UTT case – supporting LNS’ juidgment.. That’s going to be difficult to spin to even the most loyal bear. Anyone for Green on Oprah

    BTW has anyone checked BetButler for the odds of LNS saying – “nothing to see here – move along”.

    • I agree the decision will be majority for sevco this bonnie bigotland cant behave in any other way.The country is instituionly bigoted,those people WILL look after sevco and what it stands for………….A game is comming up that the the MSM is calling an O.F game between sevco + queens park Those guys realy do wish it was way back then,because thats where their thinking lies…….mon the hoops the FUTURE becons us onwards and upwards……….yours in Celtic TC…..

  11. ecojon

    @ Southern Exile

    February 5, 2013 at 10:19 pm

    You roused my curiosity so I looked at the Corsica article

    And in particular note the section:

    ‘2. Placed Shares – these shares were pre-sold to a number of institutions (but see above) subject to certain conditions. If you read the Prospectus very carefully not all of the conditions have been revealed. It is our understanding and perfectly feasible therefore that no cash has been paid to RIFC plc for these shares. Furthermore, if you read the Prospectus very carefully again, there is no definitive statement that cash is guaranteed to be received for these shares. They do ‘though have a cash value hence the Prospectus and subsequent statements refer to “Share Capital”.

    If I understand your position it is that approx £22.2 million was raised by Rangers International through the AIM Flotation. If that is the case why was it stated to hundreds of Rangers opinion-forming Bears by the club’s director of communications, in the presence of chuckles, that only £10 million had been raised.

    We all make mistakes but why wasn’t it immediately corrected or later corrected on the Rangers website?

  12. ecojon

    Just noticed that at 9.27am this morning 2,857 Rangers International shares were sold at 80.04p.

    I’m no expert in shares or the AIM Market and no doubt there are many reasons why the share price is falling back towards its 76p starting point six weeks ago from a high of 95p if I remember correctly before the end of the year.

    • As I see it, there’s still no market of a significant size. So, if the price fell to well below the starting point, it would not indicate much to me. There’s not enough shares being traded as a proportion of all shares in circulation.

      • ecojon


        I think the problem is how many shares are in circulation and I say that not in reference to lock-ins but for any equity-debt swaps that might be in operation or not as the case might be.

    • Adam

      There is only 1 reason the share price is dropping. Its a Football Club.

      As previously stated when it was coming from my side, the market cap is a ridiculous measure. The shares will be below 50p before you know it.

      • ecojon


        You may well be correct but I will reserve judgement to see what happens when the various ‘locks’ come off.

        Historically UK football clubs haven’t faired well once floated and that’s why only two, including Celtic, remained from the optimistic surge in clubs which sought UK market listings in earlier times. I have always wondered at the Rangers decision to go down the ‘market’ route to raise cash although I have to acknowlege the past expertise shown by chuckles in operating in that arena which many view as little more than a casino.

  13. Geddy Lee.


    Green learned, almost immediatley, that he did not have to explain anything to his new deluded fan base. Nor , he has found out, will the cringing Scottish media take him to task over his daily bouts of breath taking hypocrisy.

    Note how even Traynor can state that Rangers and their history are catagorically dead “No matter what Ally McCoist or Green say”, but because Green has now employed him, there’s not a word said against him on the Ranger’s forums.

    On the contrary, he has been re-invented as the only decent hack in Scotland


    Normally, his comments would have attracted death threats, and the most vile abuse you can imagine.

    It’s no wonder Green adopts the stupid attitude that he does, spreading his ignorance as he jets around the world to the most exotic locations possible, to speak to a handful of fans in the backroom of some expat pubs LOL, and all on the club’s tab.

  14. Geddy Lee.

    Adam, so why would any institutional Investor want to get involved in shares that are pre-destined to lose most of their market value?

    Do you believe Green actually “SOLD” shares to investors , or simply gave them away for a song?

    • JohnBhoy

      @Geddy Lee

      ‘Money for Nothing’ – Dire Straits.

    • Adam

      Some of the biggest entrepreneurs the world over have lost 10’s and even 100’s of millions in football. Loads of institutional investors continue to pump money into lost causes across the UK. Celtic fans have done it twice. Rangers fans have done it twice. It happens. At this point, i have no reason to disbelieve it but on the other hand, nothing surprises me anymore.

      • JohnBhoy

        “…pump money into lost causes across the UK. Celtic fans have done it twice.”

        It depends on the cause. My cause was Celtic, not profit. The purchase of Celtic shares on my part was not done with an interest in personal financial gain but with a view to contributing towards a new stadium and club stability. That was achieved. Hardly a lost cause.

  15. ecojon

    @Geddy Lee

    And the song no doubt is: ‘I belong to Glasgow’. Well at least until the time arrives to load the warchest and hitch the old warhorse to his latest yoke and seek fresh smoke and mirrors

  16. JimBhoy

    @Adam, Eco If you listen to Mick the shares will soon be worth £0.00 🙂

    Regardless, the assets will still be available to the chosen few whether that be Chico Verde, Chico Verde’s anonymous Pals, Octopus, BDO, Craigy Whyte or the Peter Lawell consortium, that’s for sure.

  17. JimBhoy

    Was there a meeting of the SFL members who could vote for the planned reconstruction last Thursday? Was there anything that came out of that? Maybe I missed that.

    • JohnBhoy


      The SFL met and agreed to “move forward to the next stage”.

      In other words, they listened paternally while Ally cried and bubbled incoherently about big boys hitting him and stealing his Star Wars figures. Then they wiped his nose with a clean handkerchief, gave him a big glass of orange and a wee sweetie to suck – he’s partial to Murray Mints – and sent him out to buy a lucky bag. Ally was only too happy to leave the grown-ups to talk about silly grown-up things.

  18. JimBhoy

    “Until such time, it remains for those Rangers supporters to do what Churchill proposed in the autumn of 1940 when he formed SOE with the purpose of setting Europe a blaze.
    Starting by torching the Daily Record and Herald’s already nose diving circulation figures. After all, there is only so much money Peter Lawwell and Celtic can give to the Record to keep it going.”

    Sticklebricks – Permanent embarrassment, permanent disgrace!!!

  19. cam

    Many Celtic fans,news editors and biased bloggers were aghast at the FTTT verdict of last November and will be elated at HMRC launching an appeal against their judgement.
    The ruling of the FTTT verdict does not affect the mindset of this blog and the appeal verdict,if it goes against us, shall be ridiculed,ignored and appealed ad infinitum, until the correct verdict is reached.
    Next paragraph redacted, due to ad hominem,playing the man,whataboutery,seasoned with a soupcon of hypocrisy.
    What the appeal does do, is allow the ballista operators many more months of fevered speculation and sweetie wifing and if succesful, shall enable Arty C to emerge from his wheelie bin.
    Some may question HMRC’s continuance with this case but they must realise that due to unlimited legal funding, they hope to exhaust into submission, any defence and use this test case to recoup funds on a country wide scale.
    In any event the appeal will,i imagine address the issue of any panel members who are not “on board”.
    I intend to write to Mr Green and his legal team and say “na na nanana” in the strongest possible terms.
    My statement above is in no way to be construed as legal advice,financial suicide or extracting the urine.
    If anyone finds it odd that i am so exercised by a matter that doesn’t affect me and doesn’t involve me then they have never heard of the phrase “revenge is a dish best blogged about continuously” and for their delectation, i shall repeat my mantra for today.
    “Na na nanana”
    posted by Paul “Ballista” McConville.

  20. cam

    Captain Traynors daily sit. rep. to Field Marshall Monty Green:

    Continual incessant sniping from the undergrowth,continued bombardment from the Thommo,PMacG,TallPaul,TSFM and Scotzine howitzers.
    The RTC gun emplacement has shown signs of new activity,situation unclear.HMRC ammunition trucks sighted.
    New regiments of orcs have been drafted in and the BDO army are reportedly setting up camp on the horizon, assisted by skirmishers of the McConvillites.
    Continued leaflet drops by enemy propaganda machinery has had no noticeable effect on troop morale and due to lack of supplies, has come in handy in the latrines.
    Cyber warfare is continuing and the enemy are jamming all comms. by using their M.I.C.K technology.Sergeant Adam is dealing with this with some success.
    The troops are prepared and wish to go on the offensive, even with the weapons embargo imposed by the plastic Generals.
    Synopsis;even with the western front secured the enemy are still obsessed and continuing with the dirty war.
    50,000 loyal Bears presence is obviously still making them nervous in their fox holes.

  21. Budweiser


    In next ‘Football Latest’ your team is now THE Random Rangers.

  22. JohnBhoy

    Hector will bleed SDM dry. Sweet justice.

  23. Geddy Lee.

    Cam, Capt traynor? He who used to be, according to the Sevco Intelligence unit, “a dirty stinking child abu……..”
    och you know the rest.

    I hope Col Whyte has approved this appointment. Traynor may have coined the phrase “Wealth off the scale” (snigger)
    but that back-fired like nobody’s business.

    Surely “Ra People’s” commisioning board MUST have asked him to explain his “no more rangers” comments before handing him a uniform?

    Dining on “succulent lamb” clearly has it’s advantages LOL. Long may he serve.

    • cam

      As to the first part of your reply,,,no i don’t know the rest and have no desire to.The subject you allude to ,is not something i wish to discuss with you.
      I shall leave you and the regimental goat to be come better acquainted.

  24. Geddy Lee.


    Capt Traynor has stated that “Mess Funds” only equate to 10 Million in terms of cash raised by the floatation.

    Surely Brigadier Green has not run off with the Mess Silver, because there’s 10 Mill missing according to Traynor’s figures. Will no one in the regiment question this incredible discrepancy, or are you all just going to ignore it as usual, and hope it just “goes away”. LOL

  25. ecojon

    Revealed: Rangers winding-up petition

    After some days of often feverish online speculation, I am now able to clarify the situation regarding the winding-up order which may soon be served against the Rangers Newco over a contract for services prior to the recent share offer.



  28. mick

    thommos well on to him lol

  29. Mr Charles wrote: “HMRC have also reaffirmed this position to the Club’s tax advisers, Deloitte.”
    That’s confusing.
    Why would the club need tax advisers?
    Are its financial affairs not the responsibility of the club’s “holding company”?

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