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"?Why? Do you think the PL have a strong case to support Etihad being any or all of:
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.
- a related party,
- not FMV,
- disguised equity investment?
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.
Says we haven’t seen anything yet.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.
They definately don't have any more shite than what UEFA spat out. Just an its important obvious.
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.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.
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.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...
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Stop being such an attention-seeking idiot. You clearly know fuck all about this issue and refuse to listen to those who do know something. But just to try to hammer some facts into your skull, I'll respond.
The evidence presented at CAS from several sources made it clear where the bulk of the Etihad sponsorship came from. It came from central Abu Dhabi marketing funds and there's nothing wrong with that. UEFA could offer no cogent evidence, other than the very selective and out-of-context hacked emails, to the contrary.
Etihad were given the money, but not by Sheikh Mansour. They paid it to us, the accounting was correct and they got full consideration for the money they paid in terms of sponsorship, plus it was considered to be a fair price for what they got.
But if you want further proof, then the Open Skies case against Emirates, Etihad and Qatar Airways provides it. There's a document on file in the New York Court, which was there well before the Der Spiegel stuff came out, which states that the Etihad sponsorship of City was funded by central Abu Dhabi funds. That was prepared around 2010 I think, certainly no late than 2012 and that document is why I was so confident that we'd succeed in our appeal to CAS.
Do you seriously think that a document was prepared in 2012 that anticipated having to cover up something that we had no idea would become an issue years later?
That’s because your story keeps Chopin and changin’He can’t Handel the truth.
I'd say that statement is technically correct. The UEFA case centred on the fact that there were two separate payments; one of c£8m and another of c£52m. UEFA's assertion was that the £52m came from ADUG. The evidence presented at CAS was that it originated from "central marketing funds". The funds weee given to Etihad, who paid them to City.Presumably the document you refer to as being on file in the New York court is the Booz Allen presentation from 2010 which hit the public domain in May 2014 when leaked in the Australian Financial Review paper.
Are you aware that during the Open Skies exchanges in 2015, Eitihad responded to the claims by the 3 American airlines in a detailed 64 page document before the US Departments of Commerce, Transportation and State - Washington , DC?
I quote from the document:
"The assertion that the Abu Dhabi government paid for Etihad’s sponsorship of English
Premier League football club Manchester City is equally false. In 2011, Etihad and Manchester
City entered into a 10 year sponsorship agreement, which included naming rights for Manchester
City’s stadium. Etihad funded this sponsorship from its own liquidity."
Unless you have something else up your sleeve to correct me (i hope you have) it seems you have put far too much emphasis on a leaked document without the full context. Ironic :)
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.