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Reply | Danny Murphy
at 11:48 4 Sep 2025
The pair of "advisers" from Kingsbridge were far from the only ones involved.
As to "charging" them - with what?
There are plenty of rules for financial and investment advisers around adequate risk warnings being issued, suitability, management etc. These are mainly concerned with the giving of partial or negligent advice and can be traced back to the regulation forced upon them by the FCA/FSA who basically underwrite advisory firms.
There is no such regulatory body for matters involving an opinion on tax. HMRC does not and will never "approve" schemes (although this was often claimed) and certainly does not police schemes, pre execution. They will not give you an opinion pre execution either.
So a QC/KC opinion is no better and no worse than Dave down the pub. |
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Reply | Tax Avoidance Schemes
at 09:59 4 Sep 2025
Some of the comments above about the moral/ethical judgements around doing something legal to avoid tax or illegal to evade tax are points we have addressed many times over the years.
One end of this spectrum says that the people we put in charge of spending our taxes (the Gov't) cannot be trusted for any number of reasons to spend it wisely or in ways that we consider are good for us, our family, our community and our country. In that priority. In order to limit the unwise spending we almost have a moral duty to reduce what we give them.
The other end of that spectrum says that we - the people - want to enjoy the benefits of a first world nation and have a moral duty to aid and assist those who often through no fault of their own cannot support themselves. Consequently we have to accept that those with more resources should contribute more to the tax pot.
Where you fit along that line is wholly subjective.
Our approach is to explain to clients that the Gov't could demand 100% of your earnings, gains, asset sale proceeds, etc. The tax legislation is there to protect taxpayers from that scenario. Where the tax law is missing, ambiguous or unclear it is better to assume that anything other than paying the maximum amount of tax will be seen as avoidance. This takes away the personal judgements as to fairness and moral stance.
It is however a very uncertain picture not helped by incompetence that is almost negligence at HMRC.
We advised on a transaction. Two brothers built a business and sold it for a lot of money (eight figures). One used a series of structures and paid around 10% of his share in tax. The other deliberately shaped his transaction to pay the maximum tax he could - around 35%. We submitted the calculations together. Both were agreed by HMRC without a whisper.
Who was "right"?
I don't know and it doesn't matter. |
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Reply | Tax Avoidance Schemes
at 09:43 4 Sep 2025
An opinion from a QC/KC is exactly that - an opinion.
It's not a free ticket, not a guaranteed outcome, just one man's opinion.
It was well known that some QC's were essentially guns for hire. Given them the "right" question and you got the "right" answer.
I'll not name them here but a QC called Jolyon Maugham - founder of the Good Law Project - wrote an article called "The boys who won't say no" which criticised named barristers. That was over ten years ago.
https://taxjustice.net/2014/08/18/8194/
(Be careful as the Tax Justice Network is run by a purist who has some odd and unworkable ideas.)
A true story.
I surveyed a group of clients (some of them pro players) who used film schemes. Total population around 1,200. Had about 900 responses. Of those, less than 30 said that they had read the QC opinion. Of that 30, less than 5 had read the instructions to the QC that he answered in his opinion.
Why?
Because tax is complicated. Because they trusted somebody who was a professional. Because they were reckless with their time and money.
Not one of them got a second opinion. Some did ask the introducer for a second opinion. Those not put off by the costs and negative reaction of the introducer said that because the second opinion did not come out and say "stay away", they saw it as approval.
Not one of them asked HMRC about the scheme BEFORE using it. (I know the TV program said otherwise but having met with and spoken with the lawyer heading the V11, I can confidently say that they have not one shred of evidence that any such conversation with HMRC took place.)
I can also say that the V11 group has been very good at exploiting the fact that they are well known names to elicit a TV program in an attempt to garner some sympathy and to counter the often harsh rhetoric of HMRC. There are tens of thousands of less well known taxpayers who are in a very similar situation who have been fighting this for close on 20 years. Sadly to my certain knowledge at least half a dozen have committed suicide. |
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Reply | Tax Avoidance Schemes
at 17:13 2 Sep 2025
The schemes used here really began with Labour's Blair and Brown who introduced tax relief for investment in British films. The budget for this relief was initially around £40m.
It worked. Many films were made here and UK studios, pre and post production and other services boomed. And Blair/Brown got to rub shoulders with Hollywood glitterati.
In the late 1990's along came outfits like Kingsbridge, Ingenious, Matrix, etc. They commoditised the tax relief. They realised that if you put in 20p/£, borrowed 80p/£ you got tax relief on £1 which at that time was worth £0.40 - or twice your investment. The 80p was paid back by the film studio who got 20p of cash.
Greedy? Yes - but who gained?
The studios = yes. The introducers = yes (30% commissions). The above firms = yes. The investors - yes, they doubled their money without worrying about the success of the film.
So who lost? British taxpayers. I would estimate that the tax relief claimed for these schemes is north of £10bn. The amount paid out and now irrecoverable is perhaps £3bn. The amount in dispute and being chased by HMRC perhaps £5bn. (Around £2bn was never paid out and claims have been abandoned).
Also losers are British studios and film workers. A different system of relief replaced these schemes but it's worth perhaps a quarter of what it was. Fewer films made in the UK since 2005 when HMRC changed the rules - see below - and as we have now seen even the big franchise "British" films like Bond are going overseas.
In 2005 HMRC "changed the interpretation" of the rules. They claimed that all relief claimed to then and not paid out was now subject to that new interpretation. The new rule basically stopped all claims and we saw a dozen or more cases go to Tribunal. They are still going some two decades later. To those of us used to tax law being tax law and changed only when Parliament said so, suddenly be subject a change in policy by HMRC (unelected)- unannounced - was a shock.
The introducers and facilitators and agencies such as those above, did one of two things.
Either they closed their doors immediately and the owners disappeared with millions in fees. Or they told investors (the players) that this was "all routine", "will be challenged", "don't worry your money is safe". Some of these firms are still saying that - Ingenious in particular.
All the time HMRC was tightening the noose and putting these firms AND THE INVESTORS on notice that they wanted the tax (which in many cases HMRC had actually paid in cash and now wanted back) and interest and probably penalties.
I have seen HMRC claim that somebody who put up £50k of cash in 2001 now owes them, tax + interest + penalties, around £250k.
Can an ex player afford that sort of multiple? Probably not.
Should the player have seen this coming? Probably not as they were sheltered by agents who were lying to them and too busy to care or to be blunt just did not - and still do not - understand this process.
Should HMRC have been more honest and open and admitted that they were very late to the party? Absolutely.
So nobody comes out of this well.
I'm often asked who is to blame and the answer is everybody above.
Should we feel sorry for players? Well, if players had a decent education, some awareness that investments and tax relief can reduce or be denied, had avenues to better investments provided by clubs (who frankly were missing in this whole process which is shocking) , then we should not feel sorry.
If however none of the above was present (and it was not), are the players victims of a financial scam which in part at least was created by HMRC?
This is my day job and I've learned that making moral judgements is pointless. Some players were duped. Some knew what was going on. Each story is different. |
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Reply | Tax Avoidance Schemes
at 11:30 2 Sep 2025
This is my work area and I've helped a lot of people, including footballers, who were involved in some of these schemes.
I'll explain more later but suffice to say that the majority of them are in a bind because they listened to the wrong people. |
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Thread | New blood and old blood
at 15:35 1 Sep 2025
Start with the starting line up last weekend.
Bazunu
Stephens
Harwood-Bellis
Wood
Roerslev
Fraser
Charles
Manning
Azaz
Robinson
Archer
You can bring in one player from last season (mandatory) and then three older players from any era, still playing or not. What does your team look like? |
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Reply | Why crusaders?
at 13:27 1 Sep 2025
I suppose that those benefiting most from stirring up divisions by repeating lies, falsehoods, dissembling and ignoring facts need a very simple symbol.
It may be that those painting red crosses etc would struggle to do a four piece jigsaw and so the simpler the better?
(Offends my understanding of history though. The most "famous" English crusader was perhaps Richard the Lionheart who spent less than six months of his reign as king actually in England and spoke French.) |
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Thread | Why crusaders?
at 11:59 1 Sep 2025
I've been bombarded this morning with pictures of masked idiots climbing lamp posts to hang flags or paint something, many of them trying to mimic what Hollywood portrays as a "uniform" word by crusaders.
The crusades were the product of religious intolerance in Europe being opposed by an expansionist culture and religion in the middle east.
(They also allowed the English to ship out a lot of second/third sons who would never inherit, to make their own fortune or not return. Sound economic reasoning).
The stated aim of the crusades was to "free Jerusalem". One campaign did that, held the city for a good while and then lost it to more local interests.
Most of the other crusades failed.
The crusaders came from all over Europe. The English component was relatively small. Mostly what is now French, German and Italian families supplied the cannon fodder. (not that the earlier campaigns had cannons of course).
So why are these deluded morons wearing a costume made up by film makers who think it represents Medieval garb?
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Reply | Delusions
at 10:44 1 Sep 2025
There is a credibility gap between those supporters who cling to visions of the team as having enough quality and depth to get us near promotion this season and those who take a more pragmatic approach.
I am in the latter camp.
First, last season will have damaged some players in terms of their faith in the club. That should not be an issue for a professional, but professionals are people too. It will come to the fore when we're chasing an equaliser away from home against a team we should be beating and where we need that extra 2% effort.
Second, I think all but one Champ side has a new manager this season. I think that will help us because I suspect that few teams have yet to settle on a tactical system that the manager wants. It's a bit of a race to get there first. I suspect that Mr Still is pretty good but he is inexperienced at this level and I think the above race is not one he will win.
Third, yet again we have done transfer business late and in effect the first team for the season will not be settled until late September/early October. That might be 6 games in. If we have 10 points from those games and not perhaps 12 or 14, the difference might be enough to deny us a chance at promotion.
Fourth, the owners are running more than one club. They want profit across the portfolio and that means we are just one asset and if they feel that player X should be moved elsewhere, that is what will happen. A manager will struggle with the uncertainty.
Lastly, the trauma of last season will take a long while to fade not only with fans but with players and staff. Add in new manager, new players, a different type of football* and realistically I'd settle for top half of the table at the end of the season.
*I was encouraged by the comment from Still after the Ipswich game when he observed that under pressure a "short pass inside" was a habit from last season that the players need to unlearn. He is absolutely correct. |
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Reply | Flags
at 19:22 29 Aug 2025
Sometimes in life adults disagree.
When children disagree there is usually a contest so that one can "win" and one inevitably therefore "loses".
Adults can hold different interpretations and "winning/losing" is not the point and we have to accept that we can grow out of such childish notions.
Think that's where we all are now.
My last word on this issue. |
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Reply | Flags
at 12:08 29 Aug 2025
As an observer I would say that a full response was given but that the chosen interpretation is not one that I reached.
The "divert, deflect, distract, attack" is a well known device of the right when fact checked. |
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Reply | Flags
at 15:12 28 Aug 2025
Much of what Reform and Fartage say is demonstrably untrue.
(For example, today they claim that an energy contract between Vince's energy company the GLA - Greater London Authority - is an example of contracts being given to Labour donors. IN fact it was agreed in 2020 when the Tories were in power).
When it comes to immigration, there seems to be no lie that Reform will not use.
They follow the Nazi and now Trump rule book which says that if you say something often enough, a good percentage of the listeners, being too lazy to go and check, will believe you. |
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Reply | Flags
at 10:00 28 Aug 2025
Pot and kettle? |
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Reply | Dibling Everton Debut Tonight
at 09:58 28 Aug 2025
He's a teenager who has arrived at a PL club with a lot expected of him. I'm not at all surprised that he was seen as a little tentative and nervous.
Hopefully as he settles in he will begin to acquire some confidence and form.
My worry for him is that he is very similar in many ways to Grealish and unless Moyes is brave enough to play them both, he may have to make a choice which will limit Dibling this season at least.
That may not be the worst thing for Dibling - a chance to learn and develop - but he has already demonstrated a degree of impatience which - as might be expected at his age - he seems to struggle with.
Good luck to him anyway. |
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Reply | 9-1
at 09:07 28 Aug 2025
Rangers were an utter shambles.
The players looked like they had met for the first time in the changing rooms before the match.
Every cross into the box - defenders stood and watched the forwards go for it.
There was no transition from back to midfield and no strength in the front line.
All very familiar.
Worse was perhaps the fact that the players seemed to have no pride in their team or their game and that will be enough to see RM out of a job before the end of next month. |
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Reply | Flags
at 16:39 27 Aug 2025
Important to remember also that from 1929 onwards, there were many acts of what might be described as terrorism by both Arab and Jewish peoples.
Arguably the modern state of Israel grew out of the movements that existed then and which the western powers failed to control.
I'm not condoning what any terrorist organisation does but at some point along the journey from disaffected outcast to founder of nations, people/organisations go from terrorist to freedom fighter.
In my head freedom fighter means attacking military or civilian infrastructure.
Terrorist means attacking the above plus civilians who get in the way.
Not a perfect definition I accept.
Both sides have long since stepped over the dividing line. |
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Reply | Does reform = anarchy?
at 16:28 27 Aug 2025
Understood on the issue of too much politics.
No I do not wish to see a repeat of the side taking we saw on Brexit.
So, a reasoned and respectful note which I will interpret as a polite "wind your neck in" and I will. |
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Reply | Bella-Kotchap gone to Verona on loan
at 13:08 27 Aug 2025
There comes a point in every squad where despite a player being good enough, he has enough baggage and ill will among the other players to warrant him being moved on.
I wish him well and hope he stays in Italy. |
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Reply | Does reform = anarchy?
at 13:04 27 Aug 2025
A poll is not a vote. Studies have shown that people will tell a pollster something because it doesn't really matter but will do something else when they're in the polling station.
Just think how many times we've seen polls predictions that are wrong. In the last election a close fought win for Labour was predicted by polls. In the end it was a landslide and all the pollsters came out blaming everything from people being untruthful to plagues of frogs for getting it wrong.
How are the "people instructing" the Labour and Tory party? Voters look at the manifesto at election time, decide how much of that they believe can be delivered and vote accordingly. Once elected, there are no more "instructions". Short of revolution there is no mechanism which can "instruct" a Gov't to do A rather than B.
The issue of immigration - legal and informal - is one that is high profile and exaggerated by those who see gain in disenchanted voters - but compared to other matters is minor.
Funding of public services; security; transport infrastructure; defence; the economy; all rank higher than a few tens of thousands of people demonised by closest fascists and seized upon by their cult followers.
Would you support a scheme which handed money to would be informal arrivals in the UK directly - or to the Gov't of the country they are in now - if it meant that your local hospital closed?
The alternative being an immigration tax to pay said people.
The root causes of immigrants coming here are wars and persecution in their country of origin, refusal of most European countries to allow them to stay there, a comparatively benign system here which takes far too much time to reach an end.
We already see Labour moving to limit appeals and send some back (one in/one out although even that has issues) and as a result total immigration has dropped by about a third.
Is that better than the Tory "send them to Africa" plan? Perhaps not but it's certainly less expensive.
This is not just a UK problem and therefore the UK alone cannot "stop the boats" or "smash the gangs" or whatever new three word slogan comes next. It needs international cooperation and as far as I can see, the Tories decided not to do that (and failed) and Labour is trying to do that (but is very slow). |
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Reply | Does reform = anarchy?
at 12:15 27 Aug 2025
I would count myself as one of those who reads the football related threads but perhaps does not contribute much.
In my view, many of the threads on the football side are repeats of the issues we have been dealing with for years.
The game is not what it was; the manager has no idea; the owners are incompetent; the players aren't trying; the tactics are wrong; the players have no loyalty; etc.
All true perhaps but all attracted thousands of words over the years and nothing much changes except the names of owners/managers/players. |
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