When Will the “Rangers” Tax Appeal Be Heard? Summer 2014? Later?

The Upper Tribunal (Tax) has on its list a case of great interest to the football fans of Scotland.

Well, actually it is listed as five separate appeals, which will however be heard at the one time.

HMRC is listed as being the appellant against the following respondents:-

• The former Rangers Football Club PLC (now RFC 2012 PLC) (in liquidation
• GM Mining Ltd
• Premier Property Group Ltd
• Murray Group Management Ltd
• Murray Group Holdings Ltd

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.

Why Did Sir David Murray Sell Rangers and Other Points – A Response to Adam

It is always good when Adam pops back in to offer us his views and thoughts, which I appreciate greatly. I also liked the Fitzcarraldo comment! He has been party to a cracking debate running on the blog as we speak, and I thought I would take advantage of my position as the blog host to write a response to some of what he has been saying tonight.

For those who have not been following the debate (and why not?) one strand of discussion has been what the Rangers debt would have been without the “Big Tax Case”, whether Lloyds wanted their money. There are a couple of points where I think something needs to be added.

First of all, here are some of Adam’s comments.

My Reaction to Comments on the Rangers/Title Stripping Prediction

I am very grateful to all of my readers and to my commenters for the debate on my last post. It is good to see everyone engaging in the civilised debate which had been one of the best features of this little nook of the Internet.

So I thought that it might be useful to comment, in my turn, on some of the observations posted to the piece.

What I should say is that the predictions I have made, (or indeed guesses!), are of what I think will happen, rather than what I think should happen. That is a discussion for another time, and probably once the matter is over and the detailed evidence is produced publicly.

To recap, I think the following:-

• Lord Nimmo Smith’s Independent SPL Commission will find Rangers (the club) guilty of breaking the rules regarding registrations and payments;
• RIFC PLC will challenge this in the courts, but fail;
• Lord Nimmo Smith’s Commission will not “strip titles” from Rangers.
• The Commission will impose a financial penalty upon “the club”.
• RIFC PLC will refuse to pay.
• A legal impasse will arise and the footballing authorities will find it very hard to decide how to proceed.

Some of the comments below were answered better than I will be able to do by others in the threads, but I have out them here to collate the relevant points.

Charles Green on How the Big Tax Case Harmed Rangers – and Why He is Wrong

Mr Green, who seemed unusually quiet for a couple of days, but was no doubt involved meeting fund managers and investors for his share issue and compiling the Share Prospectus which he told Rangers fans would be out by the middle of November, has spoken out on the official Rangers website about the Big Tax Case outcome.

You can find the whole piece here.

As the article is written on the official site by Lindsay Herron it is safe to assume, I suggest, that the commentary and narrative around Mr Green’s quotes can also be taken as the “Rangers position”.

My comments on parts of the piece are in bold below the relevant section. It is fair to say that I do not think Mr Green is correct in much of what he had to say (although I am sure that would not concern him one iota).

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CHARLES GREEN has expressed his anger and dismay at the timing of the verdict of the First Tier Tax Tribunal as it has massively affected the current status of Rangers.

Despite a concerted campaign from certain quarters, which was often hateful, that decided that Rangers were guilty of “cheating” it has been proved that is not the case.