Aviva Premiership Attendances

First topic message reminder :

I last looked at this after round 10 and will do a proper comparison at the end of the season, but discussions on Wasps problems made me consider revisiting this now. All numbers are taken from the Aviva Premiership site - which shows total attendances season to date of just under 1.4m (once the double counting of the Twickenham double header is removed).

Yet again we get confirmation that Sainst and Bath need bigger grounds (are you listening Northampton and Bath councils?)

Spoiler:

But the De Beers case gets around that because it decides tax residence on where a company is centrally managed from and obviously the shell company would be managed in Belfast by the Ulster Board. Case holds precedence in the UK courts and persusavieness over here so HRMC would still be in their rights to take the tax

but the players would be employed by a South company and Ulster would pay a renting fee for the players. The players could come to the office each week to collect their cheque. Is De Beers about profit or employement

I am talking about employement as the south company is employing them and sending them off to work and has contol over them it is employement agencey law

But the south company would be managed by the Ulster branch so falls under the De Beers case (centrally managed=resident) making it UK resident for tax purposes so the players are working for a UK company not an Irish one which takes away the Irish tax advantages.

For your idea to work the company would have to be managed by an outside party and all 4 provinces would probably have to rent players from it to stop the UK taxman from taking a claim

Also you have the whole problem of personal residence and domestile which would need all the Ulster players living south of the border before they fall under Irish tax law.

no it could be done by the IRFU its swings and roundabout ulsterRFU would still pay the wages but to the IRFU owned company the money would just be a paper trial but a real one

As Ulster is a sperater company it is irelevent that the other companies don't do it as they are separate

as not donicile they pay tax on there money brought intot he compay wihch would ba all their irish pay eg their wages

The IRFU would have do all the contracts negotitions and signings though. Ulster wouldnt be allowed to be involved at all in the management of the company or they are caught by the De Beers case. So they wouldnt be able to go out and recruit the likes of Afoa, Muller, Pieneer through the new company. It would be completly in the hands of the IRFU as to who Ulster get each year. Not something I'd expect Ulster would want so they would have to be involved in the management of the company trapping them under De Beers

As I said earlier there is a reason why they do it how they do.