Has the Court of Session Today Made a Decision Which Will Win HMRC the Big Tax Case?

I know that I am not known for the brevity of my blog posts, especially where I have substantial material to work from.

However I am going to change the habits of a blogging lifetime by writing a short post based on a long piece of source material. I will write at greater length but thought this worthy of comment now.

Remember the “Big Tax Case”? That was known, more formally, as Murray Group Holdings & Ors v Revenue & Customs [2012] UKFTT 692 (TC) (29 October 2012) and the decision can be read in full here.

The Murray Group (and predominantly “Rangers”) “won” the case to the extent that, by a two to one majority, the First Tier Tax Tribunal decided that, except in the cases where the appellant conceded otherwise, the payments which had been made via the Employee Benefit Trust structure by the employer and taken by the employee from the trusts and sub-trusts in the form of loans were not payments subject to Income Tax.

The appeal by HMRC is grinding its way towards a full hearing at the Upper Tier Tribunal and will get there eventually.

But today, in a decision running to 36 pages and over 16,000 words, the Inner House of the Court of Session has issued a  decision which, from an initial look, seems to make the job of HMRC in the appeal that much easier.

The full decision in Aberdeen Asset Management PLC v HMRC can be read here.

In this case, which was heard at the level in the court system above the Upper Tier Tribunal, the court, consisting of Lord President Gill, Lord Drummond Young and Lord Glennie, over-turned a decision of the Upper Tribunal on the operation by AAM of EBTs for its senior employees.

Whilst the facts are not identical to those in the Big Tax Case, the legal principles are closely related and the Inner House has, on my reading, made a decision which is far more in line with the minority opinion of Dr Poon in the Rangers case than with the majority.

As Lord President Gill commented in the AAM case:-

[1] The tax-avoidance scheme which has given rise to these appeals is summarised by Lord Drummond Young. The scheme involved a series of linked transactions based on the appellants’ offshore Employee Benefits Trust. The object of the scheme was to pay to senior employees and directors of the appellants large sums of money tax free. The money passed from the appellants to the EBT and thence to a series of companies, aptly named money box companies, which were incorporated offshore for each of the beneficiaries. The benefits received by the employees were expressly provided to them as part of their overall remuneration. At the stage when the money was passed from the money box to the employee, the assets of the company were effectively at the disposal of the employee. The directors were mere ciphers.

Does this not sound familiar to those of us with a keen interest in the Big Tax Case?

He added:-

[6] In a case of this kind, our concern is with the reality rather than with any simulation of reality that may be achieved by the interposition of a company, the issue of shares and the oversight of compliant directors. Looking at the matter in that way, I think that it is obvious that the employee had complete control of the company and had immediate access to its cash. The money box company was simply a conduit between the EBT and the employee. The directors’ purpose was that of compliance with the objective of the scheme.

[7] On the Ramsay principle (W T Ramsay Ltd v IRC [1982] AC 300), the transfer to the employee of shares in the company was a payment within the meaning of section 203(1) of the 1988 Act (cf Garforth v Newsmith Stainless Ltd (1978) 52 TC 522). The error of the Upper Tribunal in this case lies, in my opinion, in deciding the question on the basis of the formal legal rights that flowed from the interposition of the company. The Upper Tribunal should have looked at the obvious and inescapable reality.

In the Big Tax Case was the “obvious and inescapable reality” that the money was being paid as a “tax-efficient” way of rewarding employees, and not as a “genuine” system of truly discretionary loans? Did the majority opinion consider the “obvious and inescapable reality” of the arrangements?

Lord Drummond Young delivered the most detailed of the three opinions. He said:-

[14] … The employees benefited from the funds in the companies in a number of ways: these included receiving soft loans (loans at low interest rates or loans which would not require to be repaid) and obtaining the use of property from the company. In this way the employee received substantial financial benefits as a form of bonus…

Does reference to “soft loans” sound familiar?

[29] There was generally no discussion between the appellants and the employees regarding the benefits that might be provided by the offshore companies. There was no standard way in which the companies applied their respective funds: each company invested in different kinds of investment and/or made soft loans to the employee who held all or half of the issued shares. Employees obtained benefits from their individual company in a variety of ways. This included the making of loans by the company to the employee; the taking of assets of the company as a dividend; and the purchase of land by the money box company, where the company substituted itself as a party to land purchase agreements which an employee had concluded. The duration and value of loans granted by the offshore companies were agreed in a dialogue with the employee who had beneficial ownership of the shares. Loans were invariably granted. Such credit checks as were carried out were formal. With one exception, the loans were never repaid.

Loans never repaid?

No formal credit checks?

No applications for loans ever refused?

[31] In relation to the trusts, the First-tier Tribunal found that the edifice that had been constructed merely disguised the fact that none of the trustees exercised any real discretion but simply went through the motions to give the appearance of the application of thought leading to a reasoned decision; the reality was that each component of the structure played its part in giving effect to the decisions of the appellants’ Remuneration Committee. It was inconceivable that if the Remuneration Committee recommended that a particular employee receive a benefit or bonus, the trustees of the EBT, the FBT or the directors of the offshore company would do anything other than facilitate the benefit or bonus’s reaching the employee or being placed under his sole direction and control (paragraph 57). Moreover, the directors of the company did no more than go through the motions of checking the propriety of making loans to shareholder/employees (paragraph 59).

[34] In considering what amounts to payment for the purposes of the PAYE legislation, it is important in my opinion to bear in mind that money is a medium of exchange. In practical terms, therefore, the crucial question is whether funds have been placed in a position where as a practical matter they may be spent by the employee as he wishes; it is at that point that the employee can be said to obtain the benefit of those funds. If the PAYE legislation is construed purposively it is in my view obvious that it is such a benefit that is to be taxed. For this purpose it is not appropriate to deconstruct the precise legal nature of the employee’s rights, drawing fine distinctions according to the methods that he must adopt in order to use the funds for his benefit. The fact that the employee has practical control over the disposal of the funds is sufficient to constitute a payment for the purposes of the legislation.

The majority in the Murray case seemed to “draw fine distinctions” and to “deconstruct the precise legal nature of the rights”.

[37] The argument for the appellants was that the funds transferred to the companies were not placed unreservedly at the disposal of the employees. The only right that an employee had was ownership of the shares, and he had no clear legal right to the cash. The Scheme came to an end when the shares were issued to the employee, and did not involve transferring any right to the cash to him. In this connection reliance was placed in particular on the statement in DTE Financial Services Ltd v Wilson, supra, at paragraph 42, that for the purposes of the PAYE system payment “ordinarily means actual payment: i.e. a transfer of cash or its equivalent”. This involves focusing on the legal right enjoyed by the employee; what was required was a right to payment of cash. It was submitted that that followed from a proper analysis of the PAYE legislative code.

[38] In my opinion this opinion reads the word “payment” too narrowly in the context of the PAYE legislation. It amounts in effect to saying that for payment to occur an employee must have a direct legal “right”, in a very strict sense, to the funds that are paid, and it is not enough that the employee can, by exercising a power that has been conferred upon him, obtain the beneficial use of those funds. That involves a concentration on strict legal form rather than the substance of the transaction, and treats the form as critical. Perhaps more importantly, it takes one aspect of the complex transaction contained in the Scheme, namely whether an employee has a direct right to payment of the funds paid into the Scheme by the employer, and treats that as determinative of whether there is a “payment” to the employee. Under the Ramsay approach, however, the transaction under consideration must be viewed “realistically” (Ribeiro PJ in the Arrowtown Assets case, cited above at paragraph [25]). That clearly requires the transaction to be looked at as a commercial whole. In the present case the First-tier Tribunal expressly found that the Scheme was conceived as a whole, to channel money from the appellants to the favoured employees. When such a transaction is viewed realistically, as the unity that it was intended to be, it is apparent that the employee-shareholders had ample power to ensure the beneficial use of the funds that had been transferred by the appellants into the money box companies. The fact that powers conferred by company law might have to be exercised to achieve that purpose if the directors are not compliant does not matter; it is the substance of control, and in particular the ability to use the funds in the companies as a medium of exchange for the benefit of the employee, that is important. In this connection it should be noted that, even if funds are paid into the employee’s bank account, the employee will require to exercise a legal power in order to make beneficial use of them, namely the power to direct the bank how the funds due to him are to be applied, as by writing a cheque or directing a credit transfer. In my opinion there is no material difference between that power and the powers that the employee-shareholders in the present case had to determine the beneficial use of the funds provided by the appellants as employer. This accords with the test applied in Garforth, where Walton J held that payment occurred “when money is placed unreservedly at the disposal of directors by a company” (52 TC 529). Nothing is said there about any need for a “clear” or “direct” legal right to payment; Walton J rather considered that it was the practical ability to make use of the funds that was important.

And here is the nub of the case – what does “payment” mean?

Reading the AAM decision the court seems to adopt an approach which is markedly different from that of the majority in the Murray case.

There is still a long way to go before the Murray case is concluded. However the AAM case will be one which might be exercising the mind of the learned Mr Thornhill, the excellent QC for Murray International Holdings.

The Big Tax Case still lives!

Posted by Paul McConville

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2,308 Comments

Filed under HMRC v Rangers, Rangers

2,308 responses to “Has the Court of Session Today Made a Decision Which Will Win HMRC the Big Tax Case?

  1. graham

    jjb
    GCC , CO-OP mortgage, dodgy land deals , car park leases , corporate tax avoidance …….. TICK FUCKIN TOCK !!!!!

    It looks like we are finally getting our act together and well you know it ,
    I can almost smell the fear and desperation in some of your posts,

    You reap as you sow and what goes round comes round my man , be prepared for the backlash of all the rangers fans who you and your fellow celtic fans have been poking fun at .

    You are about to discover how un dead we really are ,

    • Ed Paisley

      There is certainly a smell Graham but I think it has more to do with your lack of personal hygiene than anything untoward at Celtic FC.

      Dodgy land deals! This is Scotland not Spain. Non payment of corporate tax? They are called reliefs and allowances. Celtic aren’t paying interest on a Eurobond loan from a parent company to reduce taxable profits – like many well known companies do. To my knowledge Celtic FC are not engaging I’m dubious CT avoidance measures.

      Celtic are prospering through thrift, honesty, hard work and positive aspiration – traditional Roman Catholic virtues.

    • Ian4300

      graham,

      You have Delusions of Adequacy.

      Just WHAT are the SEVCONIAN Horde going to do? You bunch of feckwits have been conned & fleeced rotten, TIME & AGAIN..

      Tell me The period Corporate Tax was avoided by Celtic & the amount involved.
      Tell me HOW a bunch of losers & Haters will influence a Mortgage which is paid on time & is up to date.?

      Do you have proof of dodgy deals or are your gums just flapping… AGAIN.. One thing about you is that you are Consistent… ALWAYS Wrong.

      Let’s look at Facts:

      Rangers DIED while you all stood around waiting for a Rangers Man Sugar Daddy to save you,What a Bunch o Fuds… RFC(IL) Remember.

      Then this pish patter ,” We ARE FINALLY GETTING OUR ACT TOGETHER” Jeezo if the SEVCO SHAMBLES is you getting your act together you are Easily pleased.

      What a FUD 🙂

    • Paul

      True what comes around goes around so just accept your punishment your team died.

  2. graham

    portp
    could it be you are beginning to realise that we are not dead and we never will be
    McColl & King will stop all this board room nonsense , clear out the spivs and get THE RANGERS back to being the number one club in Scotland .
    I ‘am sure you can remember when craptic had their own board room battles
    you know where no one from Rangers bothered about it ,we just let you get on with it .
    You came out of it with a new stadium and stopped our 10 in a row .
    I bet it felt fantastic for the long suffering celtic fans , but can you even begin to imagine how good this will feel when the mighty Glasgow Rangers are back and finally win the league , when we get it right up all the celtic fans who have been obsessed with kicking us when we have been down , falsely claiming we are dead and all the other pish …
    Yes OUR DAY WILL COME … this is as good as it gets for you

  3. graham

    badger ,
    the celtic fans gave the rapid player the opportunity to play act due to their actions of pelting the linesman with coins and the number of bottles and can that had been chucked onto the pitch prior to the alleged coin hitting hit him.
    like a modern day player that dives he can only do so if he is give the opportunity too , the celtic fans certainly gave the rapid player his opportunity .
    But you just rewrite history as you and your lot always do !!

    • How have I rewritten history? My point was backed up by facts which is a lot more than most of your lies on here.

      • willy wonka

        @badger, the “proof” you and others here wanted is over the page. Go back and read it and then tell us what your opinion is.
        Go on. Don’t do what the rest of them do and just ignore it. Let me know what you think.
        Lol.

  4. hector

    Saw a headline “blackout at Ibrox ” and thought oh dear the direct debit has bounced again. As it turns out it is Iain bet fred Black that is suspended.

  5. graham

    PAUL ,
    Am pleased you managed to get BRITISH passport to suit your special needs ..
    now why don’t you use it too move to one of those countries “who hate” ….
    you know WHAT I mean !!

    • Ian4300

      Hello Nazi boy,

      Your slipping again.The old Do as WE the Peepel say or get out Seig Heil.

      Your mob have Minority status, contrary to what you believe, that Right Wing Supremacist shit works while dancing on Landrovers in Belfast, it frightens the rest of us… NOT.

      Remember why That kicked off? They refused to let the Peepel march & the poor diddums all spat out the dummies & rioted, such Culture, so much decorum on the Queen’s highway, by her greatest supporters.. 🙂

      What do/did other countries “Hate” about Britain? Was it the fact Britain INVADED them?

      • graham

        You really are sick in the head ya twisting terrorist supporting anti British baw bag !!
        Now if you don’t like being British the door us open for you to fuck right off

    • Paul

      Fuck ma dug makes more sense than you .Now to say my passport is for special needs is a wee bit out of order but hey who am i to argue with a Nazi
      And also i have told you i am Scottish so will i fuck off to Scotland where i live.
      Now talking about special needs where do we start with you, take out your crayon and try A B C the a b c.Might be here a while but come back soon and we will see how you are getting on.

      • Paul

        “Now if you don’t like being British the door us open for you to fuck right off”
        Fuck leave you for two minutes and you screw up a simple sentence right get your crayon out, A B C a b c .

  6. Ed Paisley

    Good old Graham at it again – inviting people who criticise this country to ship out.
    Here’s some advice for you Graham – put on your John Bull suit and relocate yourself to Windsor. You might get a glimpse of Michael Fagan’s ex on her way to the castle that we, the anti monarchist taxpayers maintain.
    I’m waiting for Graham to give us his rhetorical whirl on “the Tiber foaming with blood” unless we control this unfettered immigration (3% ethic minority population in old Scotia).
    What did you think of those rendition flights to/from Britain authorised by Blair and Brown? You know, shuttling criminal suspects to jurisdictions where they could be tortured with impunity? Didn’t you feel a twinge of shame for our country then. Even a touch of hate for this country?

  7. @Cam
    McColl has nothing mate, A sound byte about the I.P.O. costs are auld hat, and “tits up by April.” to pick up on the CM statement that that will be their lowest point. Is that it? Maybe get some investment, Maybe have a “name” CEO! Jeezo!
    Paul Murky is just as bad, “There will at least have to be another share issue”.. At Least!!! ….So maybe more than one.!
    Here is a novel approach for them to try… Why don’t they just feckin’ apply for the job!? The address is in the paper!!!!!

  8. JOE

    So back to business Lets all laugh at Rangers.
    MMWWAA HA HA HA
    Who could forget Mr Custard.
    Mr Custard came under fire from Rangers fans who feared that the Corby clown was taking money they were sending to help the cash-strapped club.

    When the club launched a fighting fund it publicised the wrong Paypal address. And that led football fans from Rangers – and Celtic – to Cllr Bob Riley’s website for his company Bluenose Entertainments.

    Cllr Riley, who has run the business with his wife Julie for 20 years, said: “I had a few emails from fans who thought they had come to a website to make donations to the Rangers fighting fund.

    “Most of them were funny but there was one which was a bit unpleasant.

    “You had to see the funny side and I suppose the mistake ended up giving my company a bit of extra publicity.”

    The Bluenose Rangers Supporters Assembly told club fans to send an email to assembly@bluenose.co.uk.

    The correct address for making a donation to the fighting fund should have been assembly@thebluenose.co.uk.

    When supporters checked out the website http://www.bluenose.co.uk to find out how the fighting fund was going, instead of getting the latest news on the Rangers crisis they discovered a site devoted to children’s entertainers Mr and Mrs Custard.

    The club rectified the error as soon as it was pointed out to them.

    Liberal Democrat councillor Mr Riley said: “It was just a silly mistake and it was sorted out quickly.

    “I didn’t receive any donations from Rangers’ fans because it was the wrong Paypal address. Being in politics I’m used to abuse but I wasn’t really sure what was going on.

    “Because there are lots of Scottish accents in Corby, I thought someone was having a laugh.

    “The fans ended up on my website and I had a few messages.

    “I couldn’t work out what Rangers had to do with me. Most of the emails said things like ‘give us the money or we’re sending the clowns around’.”

    Mr Riley and his wife organise children’s parties and magic shows for youngsters all over the area.

    And they are normally the ones who are organising pranks to entertain their young audiences.

    Mr Riley said: “The whole thing has been a comedy of errors but it’s all sorted now.

    “There was no harm done and I haven’t had anymore emails.”

  9. JOE

    So this whole sorry slow drawn out saga has been pure comedy gold.
    From the Administration to liquidation and the mistakes on the fighting fund placards and Email address.
    From
    Spivs in Spivs, Spivs out.
    Money in Money out.
    Directors in Directors out
    Watty in Watty out
    Greig in Greig out.
    Murray’s in Murray’s out
    All the negative publicity!
    All the Lies and deceit.
    All the hurt and embarrassment for their fans.
    All the disbelief and deflection.
    Came from within all self inflicted.
    You would be hard pressed to Write a script about this lot.
    That is why we laugh and laugh and laugh.
    So come on thickos try and defend this lot.
    I suppose we will get the usual crap.
    WATP GSTQ NO SURRENDER.
    OH HOW WE LAUGH AND LAUGH.

  10. JimBhoy

    Happy Friday clatterers.. Looks like the Celtic are onto another massive profit once the auction opens for big Lurch, quotes of >£10m… Another plus for the scouting team..

    Boruc is only 33… Bring back the Holy Goalie..

    Talk about McGeady coming back for a small fee and James Forrest in demand to the tune of £8m, now that would be a great bit of business too..
    Hail Hail

  11. Jamie

    @graham

    I heard that some war vetrans in Germany are planning to sue members of the british regiment that deafend them during the war….Hope your old granda never left any assets.

    • graham

      Jamie ,
      how is the whole hunting down of the child molesters going in your church ?
      are they still just moving the guilty scum bags around and covering up for them ??
      to think my to think my grand fathers fought for ungrateful twats like you

      • Kerrygirl

        What has that got to do with football

        • Bugger all. He’s yet another vile scumbag who cant accept the loss of a football club.

          • hector

            @badgerbhoy the land deals ” scandal” was a bust so back to the orc default position child molesting a subject the sevco orcs seem to have an unhealthy interest in.

        • graham

          Kerry
          It had absolutely nothing to do with football !
          But then it was in response to a few other posts that had f all to do with football .
          They had a go at my religion , my patriotism calling me a nazi and tried to belittle my grand fathers war effiorts !
          Hope that clears it up for you

          • Kerrygirl

            That’s no excuse,

          • Ian4300

            Seig Heil Nazi boy, have now added pervert to the list of your nastiness.

          • Jamie

            @ graham

            “Kerry
            It had absolutely nothing to do with football !
            But then it was in response to a few other posts that had f all to do with football .
            They had a go at my religion , my patriotism calling me a nazi and tried to belittle my grand fathers war effiorts !
            Hope that clears it up for you”

            Where did I belittle your granda’s war effort? I deafinately think deafening the enemy is worthy of praise and this little known part of the war should be recognised….perhaps with a concert…

            you could call it “Hearing Aid”

        • Gortnamona

          Just another sick Rangers supporting scumbag – ignore

      • gra—ham, Are you on some sort of register.

      • jjbhoy

        @graham…..You are obsessed with child molestation,get some help,stop making false accusations and make that call,you’ll feel better,well no really,cos you are a HUN.You follow follow that carcass,you call,The Rangers International Football Club,so why did your club change it’s name G-spot,was it the same reason that your players left for nothing? And to think,I was sure i’d met you at medical school,you were the one in the jar!

        • Graham

          Jib
          I don’t have any fixation about it just asked thd question to a few pricks on here who find it funny to poke fun at my religion , but like yourself take offence when I ask questions about a very serious and embarrassing problem
          Within their own catholic faith !
          Now have a good weeken

          • iantm

            WHO mentioned your religion?

            Jeezo don’t tell me you think FASCISM is a Religion?

            Did you put NAZI on your Census Form the way some wrote Jedi?

            🙂

      • Jamie

        @ graham

        I am mortally offended that you think I’m ungratefull you granda fought to save my hearing.

  12. Something
    Every
    Villain
    Can
    Own

  13. lordmac

    the spivs number one requests by there partners, at this years Christmas party is, you put £10 in we take £10 out, in out, in out, we shake the bucket, harder and spin around, we do yous once over, and then turn around, that’s what we are All about, oh you put, £10 in we take £10 out, in out, in out, then we shake it all about, we pay our self plenty
    as play the arcade, in out, in out, that’s what we are, all about. ho ho ho merry xmas

  14. http://www1.skysports.com/football/news/11788/9001233/businessman-jim-mccoll-has-vowed-to-bring-stability-back-to-troubled-rangers
    ============================
    McColl talking about Green

    “Rangers are better off without him. But to be fair to him he took them out of administration and raised the IPO…………….

    you would think that someone would notify BDO to stop the liquidation process, Scotlands “billionaire” McCol has declared that Green took RFC 1872 out of administration………..unless McColl is either a blatant liar or just has not got the first idea about what happened in the real world

  15. dan

    I see the King is returning——to South Africa. What is they say, they always return to the scene of the crimes. Luuuurrrrvvviiiinnnngggg it!

    You can just so feel their pain. I find it so enjoyable I fear I’m becoming a sadist! Luuuurrrrvvvviiiinnnnggg it!

  16. hector

    Taking a quick tour of various media outlets it seems that Sally is “confused ,baffled ,puzzled ,disappointed and bewildered ” by the decision to play the Rammy cup at Easter road. He then states ” I am not going to moan about it ” after having done nothing else for the last god knows how long. Dave King back in SA cash running out messy AGM to come and another spivs out protest at Ibrox tonight. Things not looking too rosy at sevco or Glasgow Easdales as it is about to become.

  17. Graham,

    “I further do not believe that the CEO of Celtic FC attempted to negatively pre-empt any application that I might make to the SFA. I have complete confidence that the SFA will judge any future application on its merits as would be done for any person.”

    Straight from the convicted tax dodger himself so tell us again how the Celtic board have tried to stop the “glib and shameless liar” from getting on the Sevco board.

  18. hector

    Jabba no more ya beauty !

  19. dan

    They are soooooooooo fucked! And it’s wonderful! Luuuuurrrrvvviiiinnnngg it!

    Re the non-return of the King, I think Peter’s let him know by back channels that one crook is stretching it, but two——-nah!

    I know that ‘The Caddie’ says he’s passed the AIM test—but can you believe a ‘glib and shameless liar’? I think not.

    But are they shameless or what? We had one Sevconian on Superboreboard
    tonight saying they should go into admin.2 now as it won’t affect them. My God, can any group of people be so self-centered? For the good of the nation this club will hopefully disappear now. Apart from anything else it’s unseemly to witness a mass act of necrophilia every fortnight. To have to tolerate the making of love to a twice dead body would be too, too much. Let’s bury them and be done with it.

    • Ian4300

      Dan,

      I know, but it puzzles me sometimes. I’ve asked the Sevconians Who OWNS what & Who OWNS what?

      I’ve never had a proper answer, just the wait til we are back on top Timmy. or that I’m a bigot.

      I was serious, I can’t figure it out. TRFC owns NOTHING, RIFC owns the assets as far as we know.

      This means that if RIFC call in the debt TRFC is fecked.

      Is it approaching Rent Back time to the “Real Rangers men”?

      Or is it time for a disputed ownership by Craig Whyte’s Mob?

      There may be trouble Ahead

      😉

  20. Arb urns

    Sevco sevco a new club for football
    Previous sevco had a great fall
    All the kings rand and all the kings men
    Couldn’t bring sevco together again……

  21. Like this comment on CQN:-

    Eurochamps67
    12:57 on
    1 November, 2013
    I loved Peter Lawwell’s response to the question of potential conflict of interest re the Lying King’s fit and proper test.
    My reading of it was that it was ambiguous enough to
    a) question Campbell Ogilvie’s obvious conflict and
    b) lay open the question, “what conflict of interest would the Chairman of Celtic have when discussing matters concerning a new third division club who could hardly be construed as a rival of Celtic?”

    EC67

  22. Arb urns

    As it looks like a third ‘same club’ and BDO finally are growing a pair and considering clawing back RANGERS name for the benefit of creditors it occurred the ‘ same club’ could adopt a glamorous foreign sounding name,

    Liquidacion Rangers le Troisieme… The ideas started to flow could this approach improve the co- efish

    Academica de Hamilton
    Athletico Alloa
    Paisley st Mirren
    Real Reine du Sud
    Rosario Central de Midlothian
    Real Reines Parc
    Olympique Coatbrig
    Girondins de Airdrieonians

    Et

    Les Jags du Partique… Were all born useful if they ever found themselves in the position of not being able to pay their face painters……..

    FIN

    • Ian4300

      Arb,

      I was thinking of a more Germanic to go with the SEIG HEIL mentality.

      How about “Die Liquidiert Ranger-Club”

      “the liquidated ranger’s club” in German

      Sounds OK to me.

      🙂

      • Lex McLean

        Club is “Verein” in German and they would probably add the year. You can choose any one of several.

      • Graham

        Ian thirty bore 00
        I think you are a closet nazi ,,
        You really have a hard on for all things German and never stop going on and on and on about Nazi’s
        Give it a ficking rest ya nazi loving rebublican terrorist supporting baw bag

  23. http://www.dailyrecord.co.uk/sport/football/rangers-in-crisis-fans-threaten-boycott-1118508

    Can any Sevco fans tell me how the boycott is progressing against, “Any regime who wants to take Rangers into liquidation”.
    Perhaps they could also explain why they would want to boycott , said regime?……
    I just don’t understand why prominent Rangers supporters groups would refer to liquidation as “A BLACK HOLE”!
    What’s going on?

  24. mashogeandtail

    dirty orange/rangers/sevco/the rangers bass drinkers will you please hurry up and die for the sake of all NORMAL human beings

  25. Fra

    Fat Jabbas walks. Haha. Another who doesn’t do walking away.
    TICK TOCK TICK TOCK

  26. Fra

    So there we have it. Moderation for Clarkeng and David and I assume Carseon. Vile creatures of the highest order. When will we see Willy Wonka joining them Mr Mc Conville?

    Big fat Jabba sold his soul to the devil and the devil turned around and bit him on the arse. Who on earth is going to employ that piece of vermin now. He filled his pockets with the rest of the spivs. In effect, he stole money from the people he professes to love.

    Who’s next to fill their sky rockets? Longmuir? Maybe Wee willy Wonka, or is he too vile even for this rotting corpse with his hatred of all things Catholic/Irish/Green.

    Kincora boys club was a bed of Paedophillia carried out by the loyalist paramilitaries and covered up by Willies heroes, the British secret service. Even allegations of participation by senior heads of the secret service of taking part in these vile acts has been spoken about in hushed tones.

    Are all Protestant/orange/Loyalist sections of the community to be tarred with the brush of Paedophillia? I would state NO. It has little or nothing to do with the vast majority of them. Ian Paisley turned a blind eye to the goings on at Kincora. So should the catholic community then adopt a position of BIK. (Big Ian Knew)

    Grow up Willy for you do nothing but show yourself up to be an old, nasty, vile, bigot who cannot see any other way but your own. Your team has died and you cannot accept the reality of the situation. Stop blaming the Catholic community for all the ills of the world and have a look closer to home.

    We laughed and continue to laugh at this sorry sight that you worship. Hatred and nastiness seem to be in every pore of your bigoted body. You will die a very unhappy man with all your hatred stored up inside you. Let it go and free your mind.

    I invite you to join us, the Catholic/Irish/Republican/Nationalist family. You will feel cleansed. We open to our hearts to all have truly seen the light and repented all past sins. Come aboard brother for your past ways are gone. They are gone, never to return. It may be hard to accept but accept this reality. We are NOW the people.

    HAIL HAIL WILLY WONKA. You know you want to.

    • willy wonka

      Fra, Kincora Home, tragic as the disgusting things that went on there are, had nothing to do with football.
      Torbett worked for Celtic. Two of the Celtic directors worked for Torbett even after he was found guilty. The board, staff and players at Celtic deliberately covered up the ongoing systematic sexual abuse of children within their care.
      See the difference ?
      Any words of condemnation for the actions of those employed by Celtic ?

  27. Ian4300

    Clarkeng
    October 29, 2013 at 9:22 am
    If its a new holding co how can it be the same club??
    Your club was taken over and the old club was transferred to Pacific Shelf Holdings.
    It still lies there with £5m in assets and £31m in debts.
    Sound business model eh??
    ++++++++++++++++++++++++++++++++++++++++++++++++
    Ian4300
    November 2, 2013 at 1:06 am
    Clarkeng
    Let me get this right.
    IF IT’S A NEW HOLDING COMPANY HOW CAN IT BE THE SAME CLUB?
    RFC(IL) and a SEVCO Restart in The THIRD DIVISION ?
    Are ANY Bells ringing for you?

    😉

  28. portpower

    What`s in-store for jabba now?
    The speech circuit?

    sevco Tourette FC

  29. portpower

    sevco cheer-up FC

  30. portpower

    sevco loneliness FC

  31. Graham

    Silly
    Hoops
    Eeternal
    Lowlife
    Fucking
    Egotistic
    Rotten
    Shitbags

  32. Jabba has now joined the mass rank and file that has walked away,
    How much did it cost for wee Jack the mad hatter to get rid of Jabba the Gut?

    wee jack, the man that insulted the greatest ever Ranger,John Grieg ,is still on the pay roll and he is yet to apologise for his personal insult about JG.
    Loyalty ?
    would we Celtic fans, allow a wee PR guy to take money from us if he insulted our legends ?

    Sevco dragged jabba in for one thing and one thing only, to sit him down with McCoist, on caamera to retract his many articles that pointed out the simple fact that RFC 1872 was gone and that Greens Sevco/ “The Rangers” was a new club,
    if The Rangers have not stuffed enough money down Jabbas throat to silence him then his book will be well worth reading

    jabba is a fan of the Originals

  33. bill

    By Dailyrecord.co.uk
    Rebel Rangers shareholder Jim McColl urges the board to come clean on who is ‘pulling the strings’ at Ibrox
    1 Nov 2013 18:14 McCOLL released a statement following comments made by Dave King today who says an acrimonious AGM will be unavoidable as the struggle to control Rangers continues.

    Jim McColl Jim McColl Daily Record
    FORMER director Dave King today met with the two groups who are battling to control Rangers and came to the conclusion that an acrimonious AGM will be on the cards before the end of the year.

    He admitted no “consensus agreement” had been reached because “certain influential shareholders are unwilling to compromise”.

    Self-made billionaire Jim McColl, who wants Dave King back at Ibrox, has teamed up with former Blue Knight Paul Murray and ex-chairman Malcolm Murray in a bid to bring stability back to the club.

    He says it’s now clear from Dave King’s statement today that there are outside influences who are “pulling the strings” at Ibrox.

    He said: “Over the last couple of weeks we have attempted to clarify the identity of who is really behind Blue Pitch Holdings and Margarita Holdings.

    Having now reviewed the information supplied to us by the Club we are unable to identify who is really behind these two companies.

    To avoid a further messy and expensive legal process for the Club we are now calling upon the Board to do the right thing and disclose to everyone who is really in control.

    If the Board have any desire to rebuild trust with the fans then, in the interests of transparency and in light of everything that has happened in the last couple of years?, surely they must realise that they must do this as soon as possible”.

    An AGM must be held before December 31 after court action was taken to postpone the meeting.

    Bids by former director Paul Murray and three others to join the board will be discussed.

    @cam

    Having now reviewed the information supplied to us by the Club we are unable to identify who is really behind these two companies.

    You still sitting on the fence cam or are you not really interested in why

    your, rotten to the core management, will not release the details of who

    the real persons, lurking in the dark.

    Oh my god, @cam maybe they are CATHOLICS, the church of rome

    back to claim the money owned to them, by king billy from 1690, for

    supporting his battle at the boyne.

    @cam I can still hear all the catholic bells sounding all over Europe to

    celebrate king billys victory at the boyne LOL

    PS don’t forget to enlighten the orange lodge at your next meeting of the

    POPES blessings and support for his friend king billy of orange 1690

  34. daviecooperonthewing

    Complete
    Embodiment
    Loathsome
    Terrorist loving
    Insignificant
    Club.

    • Jamie

      Repulsive
      Anti-catholic
      Nuckle dragging
      Gimps
      Exploding with
      Rage cause they’re
      Skint

      • Graham

        Tut tut Jamie
        Not another spelling mistake I thought it was only daft me !!
        Nuckle am sure has K as in knuckle
        Oops !!
        Now watch you will have Kerry and Ian in your case

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