Clarification: the debt portion of “up to $1B” is from Sherpa Capital. An unannounced but probably much smaller amount of equity was raised from BMW and others.
In the UK company directors can borrow money from their companies, but if it isn't repaid after a certain duration a tax of 32.5% becomes due.
The public record[0] tells the story
Year end April 2017:
- Number of employees : 6
- Directors Loan : £238K
- Balance sheet : £154K
- Tax due : £60K
Year end April 2018:
- Number of employees : 8
- Directors Loan : £999K (prev rolled over)
- Balance sheet : £736K
- Tax due : £303K
Year end April 2019:
- Number of employees : 2
- Directors Loan : £1.27M (prev rolled over)
- Balance sheet : £1.1M
- Tax due : £307K
Year end May 2020:
- Number of employees : 1
- Directors Loan : £253K (£1.1M has been repaid)
- Balance sheet : £227K
- Tax due : £15K
Repaying the loan would have allowed for the 32.5% tax owed by the company to be reclaimed, then regular corporation tax of 19% and personal dividend/income taxes would have been paid.
My theory is that his directors loans were fully invested in personal assets (or spent), which explains why the tax wasn't ultimately paid in 2018/19. So he nerfed the company so his tax bill could paid from revenue earned between mid 2018 and early 2020. This fits with the fact that he only started rehiring seriously in 2020.
Customers effectively paid for unmaintained open source software during this time. Now of course, on the website, he brags about how much he loves customers.
I can't speak for the IoM move specifically. I know the CEO has familial connections there, but I'm sure the confluence of tax advantages helps.
They made $37bn revenue and $684m profit (presumably post-debt-payments) last year, so I don't think that line of credit will be terribly challenging for them to repay.
It's a complete mystery to me why they don't raise some capital at this valuation. They could wipe off all the debt and have a decade's worth of capex in cash for a very small dilution.
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