A reference to section 1122 of the corporate tax act 2010 ... Which to my uneducated eyes seems to say that any company operated exclusively on behalf of an individual shall be considered to be that individual ... Does this suggest someone has been channelling funds to companies?
Clubs to provide full financial records of player benefit year including any 3rd party contributions to benefit years ... Has someone been boosting salaries?
To the first point - I think this means that PRL will view any LTD company where the player is a director and that it appears that there are no employees or outgoings other than paying the director a wage or end of year dividends will not been seen as a Ltd company but as a single sole trader.
This only becomes relevant if income being paid into the LTD company is somehow related back to Sarries or associates related to Sarries.
There's nothing wrong with players earning addtional money outside of the Sarries wage (endorsements, book sales, England appearance money).
The 2nd point seems to be yet again missing the crux of the issue at hand.
The money that might be generated by the joint venture companies won't appear on the books of Sarries so aren't considered to be a company "benefit".
These are ventures between the player and Wray personally (or one of his business partners)... so the bigger question is whether the link between the player and the club, the club and Wray, and then Wray to the player constitutes a benefit that should come within the salary cap. In my view, yes.