Blumarble Capital Ltd.

If Ken & Deano balance the books and we remain in league 1 for a year or two ...... then we are more attractive to potential new buyers...... let's say for 10 million or some other number much higher than they paid for us.  Two years work and away with xx millions of pounds in pocket...not bad for two years work wouldn't you say. And before that the losses are tax write-offs to boot. Ken & Deano might not be a daft as we first thought. 

terenceanne wrote:If Ken & Deano balance the books and we remain in league 1 for a year or two ...... then we are more attractive to potential new buyers...... let's say for 10 million or some other number much higher than they paid for us.  Two years work and away with xx millions of pounds in pocket...not bad for two years work wouldn't you say. And before that the losses are tax write-offs to boot. Ken & Deano might not be a daft as we first thought. 

 People don't go in for these multi-million pound financial transactions with their eyes closed. They will have taken very good and probably very expensive financial advice before diving in. It won't be buying a football club because of their dedication to the game or because  they've always wanted to own one.
They will probably come up smelling of roses.

rammywhite wrote:

Sluffy wrote:

rammywhite wrote:

Breadman wrote:The plot thickens.....

None of this makes any sense to me.

How on earth can a third tier football club be viewed as an attractive investment opportunity?

Short of picking it up cheap, investing nowt and then selling anything that wasn't nailed down.

Odd....

Bredders, I won't blind you with science but the most attractive thing about the business are the tax losses.
If you own 75%+1 of the Ordinary shares you are a group for tax purposes and can transfer trading losses ( which are very substantial in BWFC) to other parts of the group (which are profitable) provided the tax loss making company continues to trade in the same business.
Tax law is seriously complicated but that is more often than not the reason for buying a business as apparently nonsensical as a football club

Yes, I can understand that but is Anderson's businesses paying what, say £6 million in a tax per year, to make his acquisition of Bolton worthwhile to do this?

A rhetorical question as I don't expect anyone to know his financial position.

Anderson has had a ban stopping him being a company director which has only recently been served and the only businesses he is listed as a director are the five linked BWFC businesses.

I know he has his own company Inner Circle and perhaps others too.

We know the club is making roughly £1 million per month loss until the end of June and let's say half a million per month for the next year (hence £6 million) so I don't know if or how he can transfer the loss to other parts of his 'group' and even if he could are they paying £6 million or more per year in tax to make everything worth his while?

He also resides in Switerland so I guess he does that for tax reasons more than liking of toblerone and would have thought he was already minimising his company tax liability as much as he could already.

I somehow can't believe he is already paying HMRC £6 million plus p.a. thus requiring him to take on a tax write off business such as our club.

You may well be right but it seems there most be easier controlled businesses to take over to do such a strategy than taking a punt on the car crash of a club such as we currently are.

Just my line of thinking.

There are substantial tax losses at BWFC which have accumulated over many years and these are available for group relief now and also into the future. They're only ever lost if a business is wound up, ceases to exist so you can perhaps see why the club was 'rescued' an hour before it was declared dead in the High Court.. These tax losses could well prove to be the biggest asset the club has. Andersen's  personal position is actually irrelevant- the tax losses will go to any company which is part of a tax group- essentially the 75% rule. Andersen's group (or any group that he may in future sell to) don't have to use the losses immediately- they can be carried forward indefinitely  as long as the originator of the losses (that's BWFC) stays n the same trade. As long as they are a football club the losses can be used at any time. There is a flourishing market in loss making companies being sold for their accumulated trading losses which can be group relieved against the future profits of any corporate owner. So even if Andersen can't use them this year ,they can be used at any stage in the future but the rules indicate that you should use them as soon as possible, and it makes commercial sense to do so.
Sorry to be boring- but that's a major part of the financial jiggery-pokery that's others on here have alluded to in the past

Thanks Rammy you've given the most plausible and realistic reasons I've found anywhere as to the thinking behind the investment of Anderson into the ownership of the club but even now I still can't see it being the exact fit for the following reasons.

I presume a group of companies have to be some how inter connected for the 75% tax loss transfer to be transferable but where are these other companies?

As far as I can understand it Holdsworth bought Burnden Leisure with its four off-shoot business by his Sport Shield business (of which Holdsworth holds all the shares) which in turn seems to be a very new company that has even filed its first accounts yet - so can't be paying any substantial tax to HMRC.

Even if Sports Shield was part of a larger umbrella company owned by Holdsworth I still can't see him being so successful in business to have his companies already paying millions in tax per year already.

As far as I can understand the situation Anderson was brought in as the financing partner to the purchase of the club at the last minute - wasn't the clubs purchase going to be bought in partnership with some hedge fund investment company until the last moments of the deal when they were replaced by Andersons Inner Circle.

I'm not sure how the Holdsworth/Anderson tie-up was done but it does seem we have 'joint-owners' right now.

If that really is the case Anderson would not have 75% of the shares and thus not be able to transfer the tax loss elsewhere.

Maybe the partnership is 75%/25% to Anderson (in which case shouldn't that be reported to Companies House?) and he can have access to the tax loss via Inner Circle but then the question is (rhetorically) what other group of companies does he have that he can set the tax loss against?

He is not registered at Companies House of being a Director anywhere else but at Burnden Leisure etc, but maybe Inner Circle (which I assume is privately owned by Anderson and his wife Patricia and doesn't seem to be listed in companies house nor Patricia as a director) may have business registered abroad?

If so would HMRC allow the tax loss to be set off against profits of business registered and taxed abroad?

I don't doubt you are on the right track to the understand the thinking of the take over (at least from Andersons involvement) but I still can't see the clear picture yet - maybe I never will - but thank you for fantastic efforts in trying to enlighten me and the rest of our fellow Nutters.

^ This.

What he said.

Sluffy,
Whether Andersen is a director or not isn't the main issue- its who owns the shares. The fact that he isn't a director of a company doesn't really matter. He's probably a shareholder in some companies where the directors are associates, or his wife, or even another company can be a director - it's an evil and complicated mess. A body corporate (to use the legal terms) is a person in law and can act as a person.
Being a bit imaginative I can see BWFC being sold on in the not too distant future to another body corporate (a company) when the Andersen/Holdsworth axis have stabilised the business and added value to it in the process. That new owner will itself have access to group relief of tax losses provided it owns 75% of the shares and BWFC is still in the same trade-that of a  professional football club.. Those tax losses go with the business and whoever has 75% of the ordinary equity gets access to the losses provided that its an arms length transaction which is not just hobby farming and approved by HMRC.
Whether tax losses can be relieved against overseas gains depends on the UK double tax treaties, but generally the answer is no, although EU rules do allow it for EU companies. Switzerland is not an EU member but I suspect that the UK/Switzerland double tax treaty would probably disallow it.
 The possibilities are endless- but you can bet that those advising the Axis are well aware of what they are doing.
No foreign owner ,apart perhaps from Abramovich will own football clubs in their own right- it will all be done through personal companies to harvest any benefits going and also to protect individuals against legal and bankruptcy proceedings. Look at United and the Glazers as a  prime example of how to leverage massive financial advantage from ownership- although we, of course are in a different league both metaphorically and factually.

rammywhite wrote:Sluffy,
Whether Andersen is a director or not isn't the main issue- its who owns the shares. The fact that he isn't a director of a company doesn't really matter. He's probably a shareholder in some companies where the directors are associates, or his wife, or even another company can be a director - it's an evil and complicated mess. A body corporate (to use the legal terms) is a person in law and can act as a person.
Being a bit imaginative I can see BWFC being sold on in the not too distant future to another body corporate (a company) when the Andersen/Holdsworth axis have stabilised the business and added value to it in the process. That new owner will itself have access to group relief of tax losses provided it owns 75% of the shares and BWFC is still in the same trade-that of a  professional football club.. Those tax losses go with the business and whoever has 75% of the ordinary equity gets access to the losses provided that its an arms length transaction which is not just hobby farming and approved by HMRC.
Whether tax losses can be relieved against overseas gains depends on the UK double tax treaties, but generally the answer is no, although EU rules do allow it for EU companies. Switzerland is not an EU member but I suspect that the UK/Switzerland double tax treaty would probably disallow it.
 The possibilities are endless- but you can bet that those advising the Axis are well aware of what they are doing.
No foreign owner ,apart perhaps from Abramovich will own football clubs in their own right- it will all be done through personal companies to harvest any benefits going and also to protect individuals against legal and bankruptcy proceedings. Look at United and the Glazers as a  prime example of how to leverage massive financial advantage from ownership- although we, of course are in a different league both metaphorically and factually.

Thanks Rammy, very helpful information as usual.

I did understand that it was the share ownership and not being a director that was key in transferring a tax loss but I was trying to say in my cack-handed way that as far as I can understand things Holdsworth has bought Burnden Leisure from Davies via his Sport Shield business of which he remains the only shareholder.

Interestingly Holdsworth has registered Sports Shield as a DORMANT company on the 12th April 2016?

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He is also the only share holder of Sport Shield BWFC too (as per Companies House).

I couldn't therefore square the circle as to Anderson's involvement on the basis of the tax transfer benefit (which I totally agree is almost certainly the reason for his involvement into the club) and mused (rhetorically) further as to even if he was able to apply the tax loss transfer himself, where would he apply it too, on the basis that he doesn't seem to have any obvious UK based companies to apply it to and that he is a resident of Switzerland and probably his base for his financial dealings is linked to there also.

His wife not seemingly having any company director positions also closes down another obvious lead that I had.

I've no doubt Anderson knows what he is doing and will not be losing any of his money in this venture and that it would seem completely against his best interests to let BWFC go to the wall - which is good for us (and bad for those in the ST dreaming about club ownership any time soon!) - but as of yet I can't see clearly how he can achieve this unless it is a short term venture of his to stabilise the club until someone buys out Holdsworth for the tax loss transfer rather than him himself being the user of the facility (unless of course he buys out Holdsworth himself).

Obviously I will never know Anderson's business details (they are not my business to know anyway) but I just can't see individuals who are paying millions in tax not having taken tax avoidance measures already and thus my speculation would be they are doing this in the expectation of some major company or someone super wealthy with many millions tax exposure looking for a business like BWFC to benefit from the transferable tax loss.

Hope they find them too!

It's all very murky and has an unpleasant aroma around it. They're welcome to it.
I'll stick to a simpler life.

Wow. Does anyone else have a headache after reading all that? Far too complex for me to get my tiny mind around.

Bwfc1958 wrote:Wow. Does anyone else have a headache after reading all that? Far too complex for me to get my tiny mind around.

I think you need to have an interest in this sort of thing to follow it more than claiming your mind isn't big enough - I can tell from the many posts that you have made on Nuts that you are plenty smart.

To me the vast majority of people don't seem to grasp that the owner of a football club and it fans don't necessarily want the same thing out of it.

A fan wants success, the owner wants to make money - and the two aims are not always compatible.

As a fan I want the new owner to spend a fortune and give us a team of players that will take us back to the top so I couldn't get my head around what is was that made the likes of Holdsworth want to buy the club so eagerly from Davies and how he could possibly improve us once he bought us.

To be honest I still can't get it fully but Rammy has put forward the best explanation yet that as odd as it may seem the 'debt' of the club is the bit that actually makes it attractive to some people and that was why Davies knew that no matter what he did and asked for, that the club was always going to be bought from him because going into Administration would have wiped that debt clean.

The debt can be used to offset the tax amount to be paid by other companies also owned by the owner of BWFC.

I guess in some ways you can call it as a sort of corporate tax dodge.

How that can be applied by Holdsworth and/or Anderson is really what much of the discussion above was on about as I can see the attractiveness for the deal but I can't see how the current owners can actually apply it to themselves and thus our speculation that they really are not here to asset strip the club (which for a long time seemed to be their only possible way to survive long term) but more likely keep the club afloat and sell it on again in the short term, is a more likely option.

If we can understand how the owners are thinking we can then more likely understand what is going to happen to the team itself.

That's the idea of all our financial speculation anyway!

Bwfc1958 wrote:Wow. Does anyone else have a headache after reading all that? Far too complex for me to get my tiny mind around.

Apologies 1958-it's a very complex subject but its at the heart of a lot of financial shenanigans in business and its where financial advisers and canny business people can make a lot of money.Imagine working for the Fraud Office and trying to unravel this across countries!!
To me the real question is why others weren't interested in the club from a financial angle and there must have been something else happening in the background (like Eddie asking too much initially) that frightened others off.

I want them to sell it to Roger Tamraz, at least if it goes tits up it will do so with a bit of excitement and panache. The 2 we've got just look like a couple of glorified barrow boys that bought a football club because it was cheap, without too much thought about how they are going to run it.
I also can't understand how they metaphorically got into bed together either because there doesn't appear to be a great deal of synergy between them.

Rumour has it, KA has put his share of the club up for sale at £5million.

####### FAO: Lucky Peter Piper ################


DO NOT BITE !!!!!


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Boggersbelief wrote:Rumour has it, KA has put his share of the club up for sale at £5million.

Boggersbelief wrote:Rumour has it, KA has put his share of the club up for sale at £5million.

He would have to pay someone £5million to take his share!

Breadman wrote:####### FAO: Lucky Peter Piper ################


DO NOT BITE !!!!!


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I'm being a good boy now thanks to my advanced age

whatsgoingon wrote:I want them to sell it to Roger Tamraz, at least if it goes tits up it will do so with a bit of excitement and panache. The 2 we've got just look like a couple of glorified barrow boys that bought a football club because it was cheap, without too much thought about how they are going to run it.
I also can't understand how they metaphorically got into bed together either because there doesn't appear to be a great deal of synergy between them.

Do we have conclusive proof that he was actually interested?

His representative in London issued a statement saying he was but was behind the other bidders because he had been in the process for longer, even went on to outline how he wanted to build on the assets of the club.

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not conclusive but it came from his connections not ours.

Edit- I believe his representative who issued the statement was a connection of Phil Gartside so how that works now he is no longer around I wouldn't know.

Never a shred of truth in that IMO.

Hipster_Nebula wrote:Never a shred of truth in that IMO.

So his representatives and the man himself confirmed their interest to buy bwfc and still you say there was no truth in it?