Will Absolute
New Member
The Swiss Ramble is a good site. The guy's a doctrinaire anti-Glazerite but provides a lot of interesting info.
Of course you're right in one sense. But he may have used the word tragedy to convey that it was avoidable. We were let down by a lack of FA rules, and both fans, and very much the taxpayer, were let down by lack of company law.
Glazer was allowed to claim £££millions in tax relief against the loans he used to buy the company. The tax relief on loans was intended to encourage investment in plant, machinery and workers not to be used for artificial leverage. Osbourne in opposition suggested abolishing such relief (which would have sent Man Utd and others to the wall) - he was smartly smacked around the head and dissuaded from such socialist nonsense by his betters in the party.Can you explain this?
Glazer was allowed to claim £££millions in tax relief against the loans he used to buy the company. The tax relief on loans was intended to encourage investment in plant, machinery and workers not to be used for artificial leverage. Osbourne in opposition suggested abolishing such relief (which would have sent Man Utd and others to the wall) - he was smartly smacked around the head and dissuaded from such socialist nonsense by his betters in the party.
Tax relief on interest payments doesn't impact the Exchequer negatively. Although United's tax bill is decreased, there is a corresponding increase in the tax liabilities of those receiving the interest payments. From the Exchequer's viewpoint, there would only be a change in receipts if the lenders had a different marginal tax rate to United's. The same applies to the amortisation of the issue discounts - while it reduces United's tax liabilities over a number of years, it is taxable income in the year of the issue for the banks involved (from a present value perspective, the Exchequer is actually better off as a result).
Of course it impacts the exchequer negatively which is one of the reasons the why the US has declining tax revenues. You think the Glazers or hedge funds paid UK tax on that money? Like feck they did.Tax relief on interest payments doesn't impact the Exchequer negatively. Although United's tax bill is decreased, there is a corresponding increase in the tax liabilities of those receiving the interest payments. From the Exchequer's viewpoint, there would only be a change in receipts if the lenders had a different marginal tax rate to United's. The same applies to the amortisation of the issue discounts - while it reduces United's tax liabilities over a number of years, it is taxable income in the year of the issue for the banks involved (from a present value perspective, the Exchequer is actually better off as a result).
Of course it impacts the exchequer negatively which is one of the reasons the why the US has declining tax revenues. You think the Glazers or hedge funds paid UK tax on that money? Like feck they did.
I don't understand what you're saying here. Neither Man Utd plc nor Red football incurred or paid any tax for the interest payment of senior debt or the bonds. Tax may have been withheld and offset/paid indirectly by the issuing banks as part of their corporate profits but that's another story.It's nothing to do with the Glazers. For the senior debt and the bonds, the interest payments are subject to withholding tax at the source - which means that tax is paid in the UK
I don't understand what you're saying here. Neither Man Utd plc nor Red football incurred or paid any tax for the interest payment of senior debt or the bonds. Tax may have been withheld and offset/paid indirectly by the issuing banks as part of their corporate profits but that's another story.
The taxman has lost hard on this. If we were paying dividends it would be profits that were first hit with corporation tax, then dividends tax.
Payments to foreign entities are typically subject to withholding - i.e. the interest would be paid net of taxes (which go to the Exchequer). Payments to domestic entities are taxable in the usual way. The point is that every pound of tax relief United gets as a result of the interest (or issue cost) payments is balanced by a pound of taxable income received by another entity - on which taxes are paid in the UK. It's what you would expect - the system is intended to be neutral in terms of it's treatment of factors of production. So, just as wages and salaries are a deductible expense from the point of view of the payer but taxable for the recipient, so the payments associated with the raising of capital are deductible to the payer but taxable to the recipient.
That witholding will be balanced out in their tax overall treatment. In any event it's a tax on the bank's profits which is quite separate from the tax being avoided on Man Utd profits.
It's not separate. Every pound that United avoid tax on (by paying interest or issue costs) adds a pound to the banks' taxable profits. The two are inextricably linked.
You can't have a principle where profits are only taxed once as they pass through entities. If I make cardboard box I will be taxed on any profit on it, ifyou paint it in Campbell's livery and resell it you get taxed as well.
Analogies often blur rather than illuminate but this one in your expanded example clearly sets out now that since box 1 (Man Utd) pays no tax and the profit on box 2 is offset by bank expenses there's a net loss to HMRC. As for tax neutrality I think the leveraged buy out drives a coach and horses through the principle, avoiding due tax at source and dissipating it through intermediaries.
The expanded example has nothing to do with the United situation - it was simply a response to your, somewhat erroneous, general example. As I've said repeatedly, and obviously without making any impression, every dollar offset by United is a dollar added to the taxable income of the bank. There is no direct loss to the Exchequer. And, again, the LBO simply transfers tax liabilities to the providers of the capital. It does not "dissipate them through intermediaries". I'm sure that nothing I can say will persuade you, so I guess I'll quit at this point. Pity, I hate to waste a "teachable moment".
The expanded example has nothing to do with the United situation - it was simply a response to your, somewhat erroneous, general example. As I've said repeatedly, and obviously without making any impression, every dollar offset by United is a dollar added to the taxable income of the bank. There is no direct loss to the Exchequer. And, again, the LBO simply transfers tax liabilities to the providers of the capital. It does not "dissipate them through intermediaries". I'm sure that nothing I can say will persuade you, so I guess I'll quit at this point. Pity, I hate to waste a "teachable moment".
It's nothing to do with the Glazers. For the senior debt and the bonds, the interest payments are subject to withholding tax at the source - which means that tax is paid in the UK - and the issue costs represent income earned in the UK for the issuing banks and are also taxed in the UK. The PIKs were more complex. The issue costs were taxable as UK income, but I've no idea how the notional interest is handled from a tax perspective - so there you may be correct.
..... may be made without deduction of or withholding on account of United Kingdom income tax provided that the Notes continue to be listed on a ‘‘recognised stock exchange’’ within the meaning of section 1005 of the Income Tax Act 2007 (the Income Tax Act 2007). The Luxembourg Stock Exchange is a recognised stock exchange.
The Notes will satisfy this requirement if they are officially listed in Luxembourg in accordance with provisions corresponding to those generally applicable in EEA states and are admitted to trading on the Luxembourg Stock Exchange. Provided, therefore, that the Notes remain so listed, interest on the Notes will be payable without withholding or deduction on account of United Kingdom tax.
http://swissramble.blogspot.co.uk/
"Manchester United – down £13.1 million (£44.3m - £31.2m). Although they received a minor uplift (€3 million) from being parachuted into the Europa League".
Not taking into consideration the downfall in gate receipts.
The difference in CL TV money from going out at group stage and getting to the final is really a much smaller difference than most people (myself included) would expect.
I have read that your previous year's league position has a greater bearing on income than progress in the CL itself. I've a feeling that after Liverpool won it we still got more dosh after the payout.
I usually take in interest in the accounting anorak stuff in this thread but the tax stuff even bores me to death
Payments of interest on the bonds....
Relentless, sickening Glazer-stooge.
A bridge too far - strictly for the CPA's in our midst. The Cafe discussion equivalent of the ugly kid about whom people say 'only his mother could love him'
One senior figure at a leading Premier League club claimed privately last week that United had earned the condescending tag of ‘nomoney.com’ within boardrooms because of their reluctance, or inability, to compete at the top end of the transfer market in recent seasons.
Depressing reading. Especially:
The Glazers have really got their work cut out for them at the moment, as this article makes quite clear.
It really is quite ridiculous when you think about it. The biggest club in the land; the most supporters; the highest revenue generation; the most successful. And yet we cannot compete for top players, and are known as nomoney.com.
The inability of the Glazers to successfully launch a £600 million partial flotation of the club on the Singapore Stock Exchange, combined with annual interest payments in excess of £40 million – comparable to a £30 million signing and his wages – on United’s £439 million debt, hint at further difficulties for manager Sir Alex Ferguson as he attempts to lure at least three new players to Old Trafford to strengthen his squad this summer.
This thread began at the start of 2010 and since then has been consistently debating whether the financial situation at the club could facilitate our demise. In that time we have won plenty. And yet the thread is 232 pages long. So you cant really say it only flares up when we miss out on trophies.
By Mark OgdenLast Updated: 7:55AM BST 08/05/2012
Manchester United are facing a shortfall of at least £20 million if they end the season without a trophy for the first time since 2005.
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But United will suffer an anticipated £5 million reduction in Champions League earnings next season if City win the league because of Uefa’s complex distribution formula. Under the scheme the Premier League champions receive 40 per cent of England’s television market share and the runners-up 30 per cent. The third-place team receive 20 per cent and the fourth 10 per cent.
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But having spent almost £50 million on Jones, David de Gea and Ashley Young last year, United are unlikely to invest a similarly high figure during this close season.
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One senior figure at a leading Premier League club claimed privately last week that United had earned the condescending tag of ‘nomoney.com’ within boardrooms because of their reluctance, or inability, to compete at the top end of the transfer market in recent seasons.