Utenlandske eiere i 28 av de 92 ligaklubbene - mer skattesnusk?

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Twenty-eight English clubs are now owned overseas, increasing the risk of tax avoidance

Research by the Guardian and the Tax Justice Network reveals 28 English clubs with substantial shareholdings overseas, opening up the football leagues to criticism for allowing ownership structures that could be used for tax avoidance
• Why are English clubs owned overseas? Their responses

Twenty-eight clubs in the English top four divisions are now substantially owned overseas. Photograph: The Guardian
David Conn
Tuesday 14 April 2015 17.10 BST Last modified on Tuesday 14 April 2015 18.09 BST

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Almost one in three of the 92 Premier and Football League clubs are now substantially owned overseas, including in offshore tax havens, leading to the English football leagues being accused of allowing ownership structures of clubs that could be used for tax avoidance. Research into the ownership of all the clubs by the Guardian and the campaign group the Tax Justice Network has found 28 clubs with a substantial shareholding overseas, including nine of the 20 Premier League clubs.

The Tax Justice Network, which has produced its own report, The Offshore Game, argues the ownership of football club shares via offshore companies means there is “huge potential for tax avoidance” when the clubs are sold. There is no suggestion any particular club or owner has engaged in tax avoidance; however, owners residing abroad, who hold shares in clubs through companies registered overseas, may not be liable for UK capital gains tax â€" currently 28% for higher rate, wealthier, tax payers â€" on the profits they make when they sell a club. The huge rise in offshore ownership of clubs, which were almost all UK-owned until the wave of overseas buyers moved in around a decade ago, has coincided with steepling increases in television rights and the value of clubs, in the Premier League, and in the Championship for clubs with a prospect of promotion. “The ownership of billions of pounds worth of assets through offshore shell companies means there is a huge potential for tax avoidance,” said George Turner, author of the Tax Justice Network’s report. “This should be of great concern to fans around the country, who invest so much time, commitment, emotion and money into their clubs.

“Football is not just another business and tax havens have no place in our national game, whatever the reason an owner may have for using them.”

While many of the clubs are not owned via shell companies and their locations reflect the nationalities of the businessmen who have bought the clubs â€" including Sheikh Mansour, the Abu Dhabi-based owner of Manchester City, the Malaysian owners of Queens Park Rangers and Venky’s, the Indian poultry company which owns Blackburn Rovers â€" other clubs are owned in a variety of countries widely recognised as tax havens. The Cayman Islands feature in the ownership of four clubs: Manchester United, now registered there; Birmingham City, Coventry City and Cheltenham Town.

United was re-registered in the Cayman Islands when the club was floated on the New York stock exchange in 2012, and company documents state the club is now owned by family trusts “affiliated” with the Glazer family, via companies registered in the US state of Nevada. United and the Glazers have never explained why they employ this structure and did not respond to questions about it from the Guardian.

Why are English clubs owned overseas? Their responses

The American businessman Stan Kroenke holds his 66.8% of Arsenal via a corporation, KSE UK Inc, registered in Delaware, sometimes referred to as the tax haven state of the US, because of the anonymity it affords shareholders and its taxation laws.

The club declined to say whether this means no capital gains tax will be payable if Kroenke sells his stake at a profit but he has always been described as committed to owning Arsenal in the long term and not intending to sell.

Fenway Sports Group and Randy Lerner, the US owners of Liverpool and Aston Villa respectively, declined to say in which US state their ownership companies are registered. Ellis Short, the American owner of Sunderland, still owns the club via the Jersey company, Drumaville, which the previous Irish investors, associates of the former chairman Niall Quinn, used as their ownership vehicle. A Fulham spokesperson said Shahid Khan, the club’s American owner, will shortly fold the British Virgin Islands company previously owned by Mohamed Al Fayed, and the ownership structure will become fully UK-based.

Other countries where English clubs are owned, generally classed as tax havens because of their low tax rates and corporate anonymity for shareholders, include Bermuda, the Bahamas, Jersey, the Isle of Man, the West Indies, Luxembourg and Guernsey. The clubs owned in these jurisdictions range from the very richest, including Tottenham Hotspur â€" ultimately owned by Joe Lewis in the Bahamas â€" to some of the smallest, including Cheltenham, Shrewsbury Town, and Southend United, where a substantial shareholder is Mezcal Investments, a company listed in the BVI company register.

Prem Sikka, professor of accounting at the University of Essex, said that besides the capital gains tax saving, there can also be tax advantages if the offshore owner makes loans, on which the club pays interest from the UK.

“These clubs were at the heart of their local communities and still have that tribal following, so should be rooted there,” Sikka said. “If the local ownership is removed, they cease to be clubs; they’re just businesses.”

Richard Murphy, director of Tax Research UK, said even where clubs are owned by overseas investors who have put money into their clubs, much of the additional value comes from local fans and TV subscribers paying high prices but the owners’ wealth and capital accumulates offshore.

“Football clubs are being used as speculative business opportunities,” Murphy said.

The Premier League and Football League did not directly respond to the criticism that the use of offshore tax havens and countries overseas to own locally-rooted clubs enables capital gains tax to be avoided. The Premier League stressed that all club-companies, if not the vehicles which own them, must be registered in the UK so are subject to corporation tax if they make profits.

Manchester United fans campaigning against the Glazers’ takeover have long pointed out the £525m debt imposed by the 2005 acquisition, and steepling interest paid by the club, wiped out United’s profits for years, so led to no corporation tax being paid.


The Premier League also repeatedly stresses the amount of PAYE tax its clubs pay, given the huge wages paid to top players â€" some of it due to overseas owners’ investment â€" and the upper income tax rate of 45% â€" £1.3bn was paid in taxes last year, the league said.

“In most cases where clubs’ parent companies are registered overseas, this reflects their owners’ nationality or domicile and the source of the original investment in the club,” a Premier League spokesman said. He stressed that they do not have a problem with secrecy because the league insists on being shown who clubs’ owners are.

“It is clear that overseas investment has been good for the development of the English game,” the spokesman said.

The Football League requires club owners to pass the test formerly known as “fit and proper,” and to show they have the necessary funding to keep a club competing, but a spokesman said the league is “neutral” on how a club’s ownership is structured. He also pointed to article 63 of the Treaty on the Functioning of the European Union which enshrines free movement of capital between EU states and other countries, suggesting that makes offshore ownership difficult to prevent.

Damian Collins, the Conservative MP who last year submitted a Football Governance bill to parliament, argues that capital gains tax should be made payable on the sale of football clubs, as it will be under a new law when overseas owners sell UK residential property.


Robin Osterley, the chief executive of Supporters Direct, which encourages fan ownership and involvement in the running of clubs, said it is “very concerning” so many clubs are owned offshore. He said: “This clearly creates golden opportunities to avoid paying taxes in the UK, and increases the lack of transparency and potential for obfuscation about ownership which is so harmful to the interests of the game,.

Football’s 92 clubs and four professional divisions have long been a kind of English monument, broadcasting the names of their towns and cities for almost 100 years. This is a very modern phenomenon, of the 21st century British economy, that their ownership now entails a cruise around the tax havens of the world.


http://www.theguardian.com/football/2015/apr/14/english-football-clubs-owned-abroad-tax-avoidance?CMP=share_btn_tw

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Why are English clubs owned overseas? Their responses

With almost one in three English clubs from the top four tiers of English football now owned abroad, increasing the risk of tax avoidance when they are sold, here are their responses to why they are registered overseas
• Twenty-eight overseas-owned English clubs increases tax avoidance risk

Manchester United are one of 28 clubs in the English top four divisions owned overseas. Photograph: Oli Scarff/AFP/Getty Images
David Conn
Tuesday 14 April 2015 17.07 BST Last modified on Tuesday 14 April 2015 17.12 BST

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Arsenal
Stan Kroenke, owns 66.8% via KSE UK Inc, registered in Delaware.

Response from club Declined to comment on Kroenke’s private business arrangements.

Aston Villa
Randy Lerner owns club via Reform Acquisitions LLC, registered in the US (state not identified).

Response from club Did not respond.

Birmingham City
Birmingham International Holdings owns club, registered in Cayman Islands, floated on Hong Kong stock exchange.

Response from club No comment.

Blackburn Rovers
Venkateshwara Hatcheries Pvt Ltd owns the club, registered in India.

Response from club Did not respond.

Bolton Wanderers
Fildraw private trust company owns the club, registered in Bermuda.

Response from club Did not respond.

Bournemouth
Maxim Demin owns club via AFCB Enterprises Ltd, location unidentified.

Response from club “The directors would prefer not to comment.”

Charlton Athletic
Roland Duchâtelet owns club via Staprix NV, a company registered in Belgium.

Response from club Did not respond.

Cheltenham Town
CTFC Investments Ltd a 22.4% shareholder, listed in Cayman Islands register.

Response from club “Our investors’ company is registered in another jurisdiction simply because that’s where they live.”

Coventry City
Investment funds managed by SISU Capital, and Arvo Master Fund Ltd, registered in Cayman Islands, own the club.

Response from club “The set-up structure for a fund management business is very much boiler-plate.”

Derby County
General Sports Derby Partners LLC, owns the club; registered in the US (state not identified).

Response from club Did not respond.

Fulham
Big Cat Holdings, registered in Bermuda, owns club; ultimate parent company is Cougar HoldCo London, a UK company.

Response from club “The Bermuda company is in the process of being removed and only ever existed as a temporary structure to allow Mohamed Al Fayed to sell the football club. The structure is subject to UK taxes. Shahid Khan [the new owner] is a US resident for tax purposes.”

Hartlepool United
Independent Oilfields Rentals IOR Limited owns the club, registered in Jersey.

Response from club “The ultimate owning company is in Jersey, but the club is owned by UK company IOR Ltd. IOR bought the club for football and business reasons; it was never the intention to sell the club at a gain and that has never been possible with a League One or Two club. Even if it had been, IOR Ltd are not in the business of avoiding any tax due to HMRC.”

Ipswich Town
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Marcus Evans owns 87.5% of the club via his company MEIL, registered in Bermuda.

Response from club (from the managing director, Ian Milne): “Ipswich Town is subject to tax in the UK. The long-established ownership of the wider [Marcus Evans] group pre-dates the acquisition of Ipswich Town so is irrelevant to it. Given the club is loss-making it is very unlikely there will be any gain in value of the club. You would not expect me to speculate on a theoretical future disposal of the club once Premier League status is acquired, as neither of these events has happened.”

Leicester City
The Srivaddhanaprabha family owns the club via V & A Holdings registered in Thailand. Was owned via a British Virgin Islands company until September 13, 2012.

Response from club Did not respond.

Liverpool
Fenway Sports Group owns the club, registered in the US (state not identified).

Response from club “The ownership group are not minded to comment any further on what is in the public domain.”

Manchester City
Sheikh Mansour bin Zayed Al Nahyan owns the club via Abu Dhabi United Group, registered in Abu Dhabi.

Response from club “ADUG is a holding company and to date it hasn’t done more than that. Given the size of our brought-forward losses we are unlikely to pay corporation tax in the near future. With the higher rate of tax being in PAYE (45% plus 13.8% national insurance), this is where a substantial amount of our cost (and loss) is. There is no construct of corporate entities designed to avoid straight tax compliance in the UK or other territory.”

Manchester United
Club now registered in the Cayman Islands and floated on the New York stock exchange. Owned by family trusts “affiliated” with the Glazer family via Nevada companies.

Response from club No Comment.

Millwall
Chestnut Hill Ventures LLC owns 70% of the club, registered in Delaware. Jointly controlled by John G Berylson & Richard A Smith, a Trustee of the Philip Smith Deceased Will Trust.

Response from club “John Berylson and the Philip Smith Deceased Will Trust are USA resident, both bear tax in Massachusetts and federally.” The UK holding companies could sell the club, in which case any gain would be assessed in the UK. “Should Chestnut Hill Ventures realise its investment in Millwall Holdings at a gain for tax purposes this would be allocated to the individual members of CHV in the USA.”

Preston North End
Trevor Hemmings owns the club via Wordon Ltd, registered in the Isle of Man.

Response from club No comment. Hemmings has been resident in the Isle of Man for more than 30 years, and is understood to hold his assets there.

Queens Park Rangers
Tony Fernandes, Kamarudin Meranun and Ruben Gnanalingam own 66.02% via Tune QPR Sdn Bhd, registered in Malaysia Mittal family owns 33% via Sea Dream Ltd, location not declared

Response from club No Comment.

Sheffield United
McCabe family own 50% via UK company, 50% owned by UTB LLC, registered in the West Indies, owned by family trust of Prince Abdullah bin Mosaad bin Abdulaziz Al Saud.

Response from club “Prince Abdullah is a Saudi national and it is normal for non-UK residents to hold their assets in non-UK companies. There is no intention on behalf of the owners to make a gain selling the football club but if very exceptional circumstances occurred, the owner would be UK company Blades Leisure that is fully exposed to capital gains tax.”

Sheffield Wednesday
Was owned by Milan Mandaric via UK Football Investments LLC, registered in the US (state unidentified). Now bought by the Thai investor Dejphon Chansiri.

Response from club No Comment.

Shrewsbury Town
Jefreen Holdings, listed in the British Virgin Islands, owns just under 30% of the club.

Response from club “Jefreen has been a shareholder for some eight years, and has been a passive but supportive investor. It is not the owner of the club.”

Southend United
Mezcal Investments, listed in the British Virgin Islands, owns shares in company which holds 70% of the club.

Response from club Did not respond.

Sunderland
Ellis Short owns the club via Drumaville, registered in Jersey.

Response from club Did not respond.

Tottenham Hotspur
Discretionary family trusts of Joe Lewis, resident in the Bahamas, own club via Enic International, registered in the Bahamas.

Response from club “Tottenham Hotspur Ltd is a UK entity and as such pays all UK taxes. The club is not able to comment on the taxation affairs of any shareholders or what may be their position if their shareholding in the club is sold in the future.”

Watford
Gianpaolo Pozzo owns the club via Hornets Management Sarl, registered in Luxembourg

Response from club “UK resident Gino Pozzo, son of Gianpaolo, is the sole owner of the immediate parent company, which is registered in England. There are no plans other than to create a successful long-term future for Watford.”

Woverhampton Wanderers
Steve Morgan owns the club via Bridgemere Investments, registered in Guernsey.

Response from club Did not respond.


http://www.theguardian.com/football/2015/apr/14/why-are-english-clubs-owned-abroad-their-responses