Pompey snatch last-gasp victory over taxman
"Matt, I'm going to have stop you there," Andronikou said. "I've got something very important to do... and that's finish my lunch." Enough said, Andrew.
Mr Justice Mann, however, was determined to reintroduce some suspense into the day's events. The hour-long wait for his ruling on HM Revenue & Customs' (HMRC) appeal against Portsmouth's planned escape from administration came and went in a courtroom surprisingly full of clerks, journalists, lawyers, Pompey fans and Southampton supporters.
Where is he? What does this mean? Which side looks happier? The guessing games stepped up a notch when a still-to-be-seen Mann summoned both barristers to his room.
And so it was something of a surprise when Mann slipped into his chair, breezily apologised for being late and then, with no further fanfare, dismissed HMRC's challenge and sparked Pompey celebrations.
Portsmouth's fans finally have something to cheer about. Photo: Press Association
There will be many of you wondering how Portsmouth - a club now synonymous with fantasy finances - pulled this off. The answer is simple. They may well have spent money they didn't have, achieve successes they didn't deserve and run up debts they couldn't pay, but they did not break insolvency rules - and that is all that mattered.
So HMRC's arguments about the iniquity of football's millionaires-first repayment rules, the general iffiness of clubs making "tax efficient" image rights payments to players with dubious "brand value" and the serial nature of Pompey's antics were irrelevant. This case, in Mann's opinion, boiled down to one key question.
Was the vote to decide how Pompey get out of this mess (with an agreement to pay creditors a reduced amount of the monies they are owed) organised correctly?
Before I answer that I should probably refresh your memories. English football likes its prodigal children to return to the fold with a Company Voluntary Arrangement (CVA), a deal to repay creditors a reduced amount of the money they are owed.
These deals tend to last three to seven years and can be expected to return anything from a barely-better-than-nothing 1% to a could-be-a-lot-worse 30%. Andronikou's plan for Pompey is a five-year CVA that should see every creditor get at least 20% of what they are owed.
Of course, some creditors - UK-based football clubs, leagues and players - do considerably better. They get 100% of what they are owed and they get it first.
This is the so-called "football creditors rule" and it drives HMRC nuts. That's because HMRC once enjoyed special status, too, but must now join the queue behind football's own. In no other business sector is this the case. As a result, the taxman invariably says "no" to football CVAs.
This can have disastrous consequences for clubs as they are usually penalised more points for exiting administration without a CVA than they are for going into administration in the first place. These points reductions tend to end in relegation and a further reduction in the club's value.
In order to proceed, a CVA needs the backing of 75% of the debt, not 75% of the people owed money. Plainly put, if the total debt is £100m and you are owed £25m of it, you get 25% of the votes. And anything more than 25% is a blocking vote.
That is crucial as HMRC argues it is owed £37m out of a total Pompey debt of £130m-ish (the number is hard to pin down) - more than enough voting power to block the CVA.
But when the vote came to be taken two months ago, Andronikou only gave HMRC £24m-worth of votes. This meant the CVA was approved by a healthy 81% majority.
Hold on a minute, that's cheating, isn't it?
Well, not according to the insolvency rule book or Mann.
You see, HMRC waited until two days before the vote to increase its claim from £24m to £37m. The additional £13m was for tax avoided by the club when it paid significant sums to its players, usually to offshore tax havens, for their image rights.
A recent phenomenon in British football, clubs make image rights payments so they can use their players' likenesses or names to sell tickets, shirts and other merchandise. It has quickly become common for 15% of a player's remuneration to come in this form, which is handy as these payments are taxed at a much lower rate than income tax.
HMRC, unsurprisingly, is not convinced every player at every club has an image that generates the kind of business 15% of a typical Premier League salary would warrant. This is probably a fair point and one the taxman intends to pursue in these days of austerity.
But returning to the matter in hand, Andronikou was within his rights to say, "Woah, where did that £13m come from?" Or words to that effect.
He could not be expected to verify that amount in the time available - as is his duty - so HMRC could not be given the additional votes. The rest is history.
So where does all this leave the soap opera that is Portsmouth and the more serious drama of HMRC's assault on football?
For the club, Thursday's victory is huge. So conclusive was Mann's judgement that HMRC said it would not be appealing. This was a surprise as it had strongly indicated that it would not take defeat lying down.
Andronikou can now push on with his CVA and press the Football League to lift the transfer embargo on the club. Manager Steve Cotterill will be delighted as he is currently limited to 20 players and is without a goalkeeper at the moment, with the season due to start on Saturday.
The biggest tranche of the first annual "parachute payment" from the Premier League was due at Fratton Park on Thursday but that £9m (much of the rest has been spent already) will be transferred directly to UK football creditors by the Premier League. This should leave Pompey debt-free on that front.
The next step will be to complete the return of the club to its most recent owner Balram Chainrai, who is currently working his way through the Football League's beefed-up fit and proper person test (now renamed as the Owners and Directors' Test).
The Hong Kong-based businessman claims to have become the club's fourth owner last season almost by accident but he is now keen to take it on again. A deal to buy the club out of administration is in the works and Pompey's assets will be transferred to a new Chainrai-owned company.
This could happen in weeks, although the old company - Portsmouth City Football Club Ltd - will continue in administration for nine months until liquidation. A thorough investigation into what has been going on at Fratton Park in recent years can then take place.
The amount Chainrai will pay for his new, largely debt-free team will be what it costs to fund the CVA over the next five years, approximately £15m, with the first £3m payment coming in the autumn.
That this should come to pass will upset some fans as much as it has annoyed HMRC, which must now write off 80% of its debt, but a Pompey out of administration, in the Championship and without massive debt or a points handicap is considerably more attractive to bidders than any realistic alternative.
I am reliably told there is somebody "on the inside rail" who will come on much harder now the threat of liquidation has passed.
What next for HMRC, and its increasingly fraught relationship with football, is far less certain and far more interesting (with apologies to Pompey fans).
This was a bad defeat but that does not mean it was not a fight worth fighting. Points have been made and football has noticed.
The Premier League, for example, was represented in court on Thursday and I understand it wrote to the judge to explain just how important the football creditors rule is for the integrity of the competition.
That, and what HMRC views as an industry-wide abuse of image rights, will be the next taxman v football battle and nothing Mann said this week should prejudice how that goes.
We await a date for that one - the Premier League has already counter-attacked with a challenge to have it nipped in the bud - but in the meantime I intend to watch some football. You know, actual football. Let's hope it catches on.