IOM Covid removing restrictions

[Lost Login]

14 minutes ago, Gladys said:

Just read LL's post that explains possible motivations.  Thank you.

Still not sure how the substance rules are dealt with though. 

Firstly a company would have to have relevant income so if you are a holding company and no dividends are paid to you then there is no issue re substance. Secondly if the IoM Companies are tax resident elsewhere then they can apply to cease to be tax resident in the IoM. Practice note 208-20 https://www.gov.im/media/1367940/pn208-20.pdf

Substance legislation only applies if you have relevant income and are IoM Tax resident.

[Gladys]

2 minutes ago, offshoremanxman said:

It doesn’t really matter whether there is/was flawed advice, no advice, or a 26 page report from tax counsel. The commentators in the UK are speculating whether it’s been done for tax reasons or whether there is some other purpose. The IOM is a low tax centre after all. It’s reasonable speculation given the contracts awarded right after the re-structure were absolutely massive and were supposedly awarded as a result of lobbying by an MP who is now the subject of a sleaze investigation. Elsewhere that same company also sponsors the Grand National where the lobbyists wife, who subsequently committed suicide, was on the organizing committee.

Personally further to a protracted exchange above I found the same land holdings and mortgage links at UK registry that LL did through another company 75% owned by the IOM company and that is plausible. But the entire point of my posts is that it looks dodgy time-wise at first glance so you can’t blame UK commentators for speculating. 

Well, I couldn't be arsed doing the slog that LL did, but on the 'sniff test' it didn't look like a tax structure.

Frankly, I don't consider Mr Ethical as a "commentator". 

[Gladys]

7 minutes ago, Lost Login said:

Firstly a company would have to have relevant income so if you are a holding company and no dividends are paid to you then there is no issue re substance. Secondly if the IoM Companies are tax resident elsewhere then they can apply to cease to be tax resident in the IoM. Practice note 208-20 https://www.gov.im/media/1367940/pn208-20.pdf

Substance legislation only applies if you have relevant income and are IoM Tax resident.

Thanks, of course, I remember those additional aspects now.  It's a couple of years since I was directly involved in the industry, so thanks for the  nudge. 

[Gladys]

11 minutes ago, offshoremanxman said:

He’s got 52,000 Twitter followers so he’s about 17 times more popular than Rachel Glover. 

The Grumpy Cat had over 1.5m on Twitter, it didn't make her a financial expert. 

[Lost Login]

38 minutes ago, Gladys said:

Well, I couldn't be arsed doing the slog that LL did, but on the 'sniff test' it didn't look like a tax structure.

Frankly, I don't consider Mr Ethical as a "commentator". 

Especially when the accounts for the year ended 30 June 2020 report that there was  £3.8m UK corporation tax liability and over £6m was paid in UK social security costs which is generally employers NI. 

If there is anything "dodgy" going on I suspect it has nothing to do with the IoM and the restructuring but more to do with how the Conservative Government appeared happy to dish out contracts for large sums of monies to companies in the UK where having some connection to the conservatives seemed a pre requisite. Knowing Nick Hancock through the local pub seemed more important in getting a contract than having any actual experience in producing the items covered in the contract.

When this all blows over I think the awarding of roughly £20billion in contracts without any competitive tendering and a fair amount to companies with connections to the conservatives should be the big area for investigating

 https://www.itv.com/news/2021-04-21/coronavirus-contracts-worth-37bn-raise-corruption-concerns-report-saysn

https://www.ft.com/content/ca80611a-d020-4f17-ba99-c75350e1bed1

After all the UK Government have already been found guilty of awarding illegally a coronavirus contract to a firm run by friends of Michael Gove and Dominic Cummings.

[TheTeapot]

To the surprise of no one

 

"The findings of this cross-sectional analysis of a large, population-based French cohort suggest that persistent physical symptoms after COVID-19 infection may be associated more with the belief in having been infected with SARS-CoV-2 than with having laboratory-confirmed COVID-19 infection."

https://jamanetwork.com/journals/jamainternalmedicine/fullarticle/2785832

 

Edited November 9, 2021 by TheTeapot

[Ramseyboi]

1 hour ago, TheTeapot said:

To the surprise of no one

 

"The findings of this cross-sectional analysis of a large, population-based French cohort suggest that persistent physical symptoms after COVID-19 infection may be associated more with the belief in having been infected with SARS-CoV-2 than with having laboratory-confirmed COVID-19 infection."

https://jamanetwork.com/journals/jamainternalmedicine/fullarticle/2785832

 

What will the long covid stress heads stress about now?

[TheTeapot]

1 minute ago, Ramseyboi said:

What will the long covid stress heads stress about now?

They could stress about the lack of PLAN B, you know, masks and passports like they have in Europe where everything is so much better...

[Ramseyboi]

1 minute ago, TheTeapot said:

They could stress about the lack of PLAN B, you know, masks and passports like they have in Europe where everything is so much better...

It really is all starting to come home to roost now.

I have long believed that having the virus circulate relatively freely is actually good in the long term.

Everywhere is going to get to the same point eventually, all lockdowns and mitigations do is slow that process down (which is sensible, early doors and pre vaccine)

Now we need to keep vaccinated and let nature do it’s things.

New Zealand etc are stuffed!!

 

[The Phantom]

12 hours ago, offshoremanxman said:

But the entire point of my posts is that it looks dodgy time-wise at first glance so you can’t blame UK commentators for speculating. 

I dealt with something similar, but the other way round.  Very odd structuring for an Group with a Charity at the top of the structure I was dealing with and no sensible rationale for it.  Raised it with the AG and was told "just because it looks weird is no reason to investigate it further or assume wrong doing". 

13 hours ago, Lost Login said:

 If I had to put money on it then my guess is that this was a re-organisation that had nothing to do with tax but provided a bit of privacy whilst also separating investments assets from the operating companies so that if one or other went bang the other was protected. I expect there are several hundred, if not more, similar structures operating today in the IoM for the same reason.

Agreed, possibly just privacy, avoiding the requirement for consolidated group accounts and a bit of insulation from other activities.  I've seen this done quite a bit. 

[The Phantom]

14 minutes ago, Ramseyboi said:

 

New Zealand etc are stuffed!!

 

Yup.  It's been interesting to see how infected the Island got when we opened up.  It seems the population resistance and immunity in the UK has been due to a large portion of the population catching covid at a 'steady' rate over the last 18 months.

We didn't have that, virtually no one had covid in comparison to the UK and we relied mostly on the vaccine for resistance.  Luckily it seems to be working in terms of serious illness associated, but certainly the numbers getting infected were/are pretty scary.

NZ are going to see the same thing when they open up (if ever) except times 1000.  It's going to put their health service under massive strain.  They've simply delayed the inevitable and will receive it in one massive hit rather than being staggered.

Shame really, I thought Arden did quite well initially.  But now she just comes across as a scared mum. 

[Ramseyboi]

8 minutes ago, The Phantom said:

Yup.  It's been interesting to see how infected the Island got when we opened up.  It seems the population resistance and immunity in the UK has been due to a large portion of the population catching covid at a 'steady' rate over the last 18 months.

We didn't have that, virtually no one had covid in comparison to the UK and we relied mostly on the vaccine for resistance.  Luckily it seems to be working in terms of serious illness associated, but certainly the numbers getting infected were/are pretty scary.

NZ are going to see the same thing when they open up (if ever) except times 1000.  It's going to put their health service under massive strain.  They've simply delayed the inevitable and will receive it in one massive hit rather than being staggered.

Shame really, I thought Arden did quite well initially.  But now she just comes across as a scared mum. 

After a few blips pre vaccine I am more than happy with where we are right now.  We just need to see the remaining completely pointless restrictions which still prevent unvaccinated people from the UK coming here at all and all is well again.

[Gladys]

28 minutes ago, The Phantom said:

I dealt with something similar, but the other way round.  Very odd structuring for an Group with a Charity at the top of the structure I was dealing with and no sensible rationale for it.  Raised it with the AG and was told "just because it looks weird is no reason to investigate it further or assume wrong doing". 

Agreed, possibly just privacy, avoiding the requirement for consolidated group accounts and a bit of insulation from other activities.  I've seen this done quite a bit. 

Interesting response from the AG, presumably the service provider should have queried the advice and rationale for the structure?  Out of interest, why did you raise it with the AG? 

But yes, you are right, there are numerous reasons for some structures and certainly for Irish clients the non-consolidation aspect is a big factor. Some of them look odd with no obvious reasoning, but you do need to get the rationale.

[The Phantom]

3 minutes ago, Gladys said:

Out of interest, why did you raise it with the AG? 

 

Came to an agreement in principle for a deal with a company that was owned by the Charity.  When they went to the Charity Trustees for approval (which allegedly they didn't need to get anyway) the Charity shot it down and told them they couldn't proceed.  The only reason I could determine was that the Trustees were being obstructive dicks, so I started digging into the whole structure and it was just frankly weird with no sensible rationale.  As Charities are 'public interest' and I could see their Accounts (which also looked weird) so raised it with the AG to get their input.  As noted they basically just said 'weird' is not a reason for to investigate.

[Ramseyboi]

7 minutes ago, offshoremanxman said:

New Zealand and Australia are going to come out of this all looking very stupid indeed. It’s going to take years for them to integrate back with the rest of the world.

The really scary bit is that there was a significant portion of our population who would have happily seen us go the same way, and who were livid and scared to death when our borders largely reopened.

Projections of Nobles overflowing, hundreds of deaths and more lockdowns within weeks of us opening up again before “everyone was vaccinated” have been shown to be utter garbage so I only hope that people consider how useless virtually every prediction has been when considering this upcoming winter.

Bring on the cosy nights and the Christmas party season and let people have all the fun they deserve after what for many of us has been a very difficult two years.

Open the borders properly, stop reporting figures, get the teachers out of masks, and let us all just crack on as normal.