PL charge City for alleged breaches of financial rules

Honestly, I don’t know why you do this to yourselves. United haven’t had shareholder money for more than a decade aside from Ratcliffe which would have been checked by English lawyers. All of the money has been loans from well established institutions. There is no story here.
Yep and it only adds up to a mere billion.
 
I'd still like to know why a supposedly independent non-executive director was burning the midnight oil over an operational issue, when a NED is supposed to be detached from the day-to-day running of the organisation.

And that's yet another example of getting an honour just for doing the job you're supposed to be doing.
Or rather doing a job you’re not supposed to be doing.
 
My view is that all PL clubs should be companies, partnerships, charities, or trusts registered in the UK. Domiciling in a tax haven is just an attempt to gain financial advantage.

What tax advantage do you think it gets them?

This is a serious question. I am a tax professional, and I don't think there is one for the clubs who have done this. It's a popular misconception.
 
Because they haven't
Why? Do you think the PL have a strong case to support Etihad being any or all of:
  • a related party,
  • not FMV,
  • disguised equity investment?
I'm pretty certain you've discounted all these possibilities in your previous posts and have said that the PL are unlikely to be able to prove these particular charges.

You've made the point that, via disclosure, the PL will have access to far more documents than CAS were presented with. But that doesn't necessarily mean their evidence is any stronger than UEFA's. There's just more of it and it's virtually inconceivable that everyone lied through their teeth at CAS when presenting evidence on our behalf about the Etihad sponsorship. It could be that the PL are simply going to go down the same route as UEFA over Etihad, hopefully with the same outcome.

Of course we are assuming Etihad is at the core of the first group of charges but we may be wrong, and they may be going after Etisalat or other AD-based sponsorships, which weren't tested at CAS.

The fundamental difference we have over this whole case is the PL's motivation. I'm a cynic about that, along with others, believing that this is part of a coordinated attack on us by other clubs, and that proving the charges isn't necessarily the overall objective. You believe the PL is acting independently of some of its members and has brought this case purely on the strength of the evidence they have. I don't think our chairman shares your view, and club officials I've spoken to certainly don't.

We'll hopefully know one way or the other in the next 2-3 months.
 
What tax advantage do you think it gets them?

This is a serious question. I am a tax professional, and I don't think there is one for the clubs who have done this. It's a popular misconception.
No corporation or capital gains taxes.?
 
No corporation or capital gains taxes.?
It would take a long time to explain, but basically no:

- any profits from the trade of running a football club will unavoidably be taxed in the UK (largely a moot question, as the clubs rarely turn a profit for corporation tax purposes). Even if the trading club is registered in a tax haven these profits will still be taxable in the UK.

- A capital gain would be taxable depending on who made the sale, but if a UK company were to sell a football club it would probably not be subject to corporation tax on capital gains. A UK individual would, but that would still be true if the company being sold were registered in a tax haven.

It is also now very hard to extract cash tax free via a shareholder loan from a tax haven. So there are very few meaningful tax benefits IMO.

There can be marginal savings on things like stamp duty (very very marginal), and the use of a company in a tax haven may have some benefits for the non-UK tax position of individual shareholders, but this is very case by case. You certainly can't avoid tax in football (or any industry really) just by sticking a tax haven company at the top of the group. That may have worked in the 80s, but not now.

PSR is a much bigger concern for PL clubs now than tax ever was, to be honest.
 
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Why? Do you think the PL have a strong case to support Etihad being any or all of:
  • a related party,
  • not FMV,
  • disguised equity investment?
I'm pretty certain you've discounted all these possibilities in your previous posts and have said that the PL are unlikely to be able to prove these particular charges.

You've made the point that, via disclosure, the PL will have access to far more documents than CAS were presented with. But that doesn't necessarily mean their evidence is any stronger than UEFA's. There's just more of it and it's virtually inconceivable that everyone lied through their teeth at CAS when presenting evidence on our behalf about the Etihad sponsorship. It could be that the PL are simply going to go down the same route as UEFA over Etihad, hopefully with the same outcome.

Of course we are assuming Etihad is at the core of the first group of charges but we may be wrong, and they may be going after Etisalat or other AD-based sponsorships, which weren't tested at CAS.

The fundamental difference we have over this whole case is the PL's motivation. I'm a cynic about that, along with others, believing that this is part of a coordinated attack on us by other clubs, and that proving the charges isn't necessarily the overall objective. You believe the PL is acting independently of some of its members and has brought this case purely on the strength of the evidence they have. I don't think our chairman shares your view, and club officials I've spoken to certainly don't.

We'll hopefully know one way or the other in the next 2-3 months.
They definately don't have any more shite than what UEFA spat out. Just a downright rehash.
 
Stadium expansion and surrounding areas at a vast cost ( nothing halted)
Pep extension
A lot of talk of re building the squad over next couple of windows ( which will cost a lot)
Silver lake taking a bigger percentage in the CFG.
All says to me there is not 1 bit of worry around about this hearing from the owners/investors in our club. This is why I'm ultra confident we will be cleared on all charges maybe barring non cooperation.
 
Why? Do you think the PL have a strong case to support Etihad being any or all of:
  • a related party,
  • not FMV,
  • disguised equity investment?
I'm pretty certain you've discounted all these possibilities in your previous posts and have said that the PL are unlikely to be able to prove these particular charges.

You've made the point that, via disclosure, the PL will have access to far more documents than CAS were presented with. But that doesn't necessarily mean their evidence is any stronger than UEFA's. There's just more of it and it's virtually inconceivable that everyone lied through their teeth at CAS when presenting evidence on our behalf about the Etihad sponsorship. It could be that the PL are simply going to go down the same route as UEFA over Etihad, hopefully with the same outcome.

Of course we are assuming Etihad is at the core of the first group of charges but we may be wrong, and they may be going after Etisalat or other AD-based sponsorships, which weren't tested at CAS.

The fundamental difference we have over this whole case is the PL's motivation. I'm a cynic about that, along with others, believing that this is part of a coordinated attack on us by other clubs, and that proving the charges isn't necessarily the overall objective. You believe the PL is acting independently of some of its members and has brought this case purely on the strength of the evidence they have. I don't think our chairman shares your view, and club officials I've spoken to certainly don't.

We'll hopefully know one way or the other in the next 2-3 months.
It's the culmination of the joint project started without doubt by David Gill, that's why he moved into UEFA to ensure the implementation, what we'll never know is why Pinto targeted us, ie was he paid directly or motivated indirectly by the UEFA charges. This was backed up by PL pressure applied by the cartel and is as clear as day when you read the letter from 2012...
1000009452.jpg1000012729.jpg
 
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It's the culmination of the joint project started without doubt by David Gill, that's why he moved into UEFA to ensure the implementation, what we'll never know is why Pinto targeted us, ie was he paid directly or motivated indirectly by the UEFA charges. This was backed up by PL pressure applied by the cartel and is as clear as day when you read the letter from 2012...
View attachment 141856
Wankers!
 
Why? Do you think the PL have a strong case to support Etihad being any or all of:
  • a related party,
  • not FMV,
  • disguised equity investment?
I'm pretty certain you've discounted all these possibilities in your previous posts and have said that the PL are unlikely to be able to prove these particular charges.

You've made the point that, via disclosure, the PL will have access to far more documents than CAS were presented with. But that doesn't necessarily mean their evidence is any stronger than UEFA's. There's just more of it and it's virtually inconceivable that everyone lied through their teeth at CAS when presenting evidence on our behalf about the Etihad sponsorship. It could be that the PL are simply going to go down the same route as UEFA over Etihad, hopefully with the same outcome.

Of course we are assuming Etihad is at the core of the first group of charges but we may be wrong, and they may be going after Etisalat or other AD-based sponsorships, which weren't tested at CAS.

The fundamental difference we have over this whole case is the PL's motivation. I'm a cynic about that, along with others, believing that this is part of a coordinated attack on us by other clubs, and that proving the charges isn't necessarily the overall objective. You believe the PL is acting independently of some of its members and has brought this case purely on the strength of the evidence they have. I don't think our chairman shares your view, and club officials I've spoken to certainly don't.

We'll hopefully know one way or the other in the next 2-3 months.
How can the PL board be acting independently of its members when the media have been given information about the case (damaging to City) which could only have come from someone on the PL legal team (very highly unlikely) or because someone in the PL leadership team has spoken to a rival Club Director who has blabbed it to the media? Who briefed the Times about the contrived "115 charges"?
 
It would take a long time to explain, but basically no:

- any profits from the trade of running a football club will unavoidably be taxed in the UK (largely a moot question, as the clubs rarely turn a profit for corporation tax purposes). Even if the trading club is registered in a tax haven these profits will still be taxable in the UK.

- A capital gain would be taxable depending on who made the sale, but if a UK company were to sell a football club it would probably not be subject to corporation tax on capital gains. A UK individual would, but that would still be true if the company being sold were registered in a tax haven.

It is also now very hard to extract cash tax free via a shareholder loan from a tax haven. So there are very few meaningful tax benefits IMO.

There can be marginal savings on things like stamp duty (very very marginal), and the use of a company in a tax haven may have some benefits for the non-UK tax position of individual shareholders, but this is very case by case. You certainly can't avoid tax in football (or any industry really) just by sticking a tax haven company at the top of the group. That may have worked in the 80s, but not now.

PSR is a much bigger concern for PL clubs now than tax ever was, to be honest.
Thanks for that. I understand that the UK has been very active in the field of international tax affairs and have tightened up considerably in the last 10 or 20 years. Your answer however assumes uk activity. Let me pose a different question to your expertise. Most big clubs are now going down the multi club route pioneered by City. Many transactions will not be between a uk company and an another party. For example, MUFC has a corporate structure comprising 15-20 companies. Many of its trades will not touch the uk. If the company entering such a transaction is registered elsewhere and has no presence here, its world wide profits would not be subject to uk tax, whereas if it were registered here, it would be so subject.
I will desist from asking you about a group operating out of Delaware’s tax regime. But in the example I have given, is there not an advantage to the group?
Would CFG eventually find some advantage in moving its registration, offices etc out of UK?
 
It's the culmination of the joint project started without doubt by David Gill, that's why he moved into UEFA to ensure the implementation, what we'll never know is why Pinto targeted us, ie was he paid directly or motivated indirectly by the UEFA charges. This was backed up by PL pressure applied by the cartel and is as clear as day when you read the letter from 2012...
View attachment 141856View attachment 141859
I am sure this is correct but don't think Pinto targeted us because our emails were a miniscule portion of tens of millions of documents hacked by Pinto. His MO was to trawl for data and either sell it to the media or try to blackmail organisations. He was caught bang to rights, complete with his secret Swiss bank accounts. We were just collateral damage. None of the charges against Pinto (up to now) relate to City. It is not clear how or why Der Spiegl got the information. Perhaps they just paid Pinto for it because it was a good story.
 

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