30 mars 2011 - The payable was described as a “potential liability” of £2.8M subject to “continuing discussions between The Club and HM Revenue and Customs" by RFC Auditors Grant Thornton in a letter

Description:

Grant Thornton, Auditors to RFC, provide a letter in support of RFC’s UEFA Licence application, confirming that all payroll taxes have been paid by the due dates, but “with the exception of the continuing discussion between HM Revenue and Customs in relation to a potential liability of £2.8m“
That statement is at odds with the known positions of acceptance of a liability on 18 February 2011 and agreement as to the amount on 21 March 2011 between HMRC, MIH and RFC and that payment was due. Nor is there any indication of any “continuing discussion” between the parties.

The earlier meeting with Cairn Financial made reference to the liability having to be paid by 31 March 2011. That date is consistent with a need for clubs to have no “overdue payables” as defined by the UEFA Article 50, where proof of such in order to secure a UEFA Licence for the following season is required. The SFA’s position on proof of compliance was documented in the same source email that referenced the Grant Thornton letter.