Manx Heritage Foundation: TIME TO REMEMBER: Mark Moroney MANX HERITAGE FOUNDATION ORAL HISTORY PROJECT ORAL HISTORY TRANSCRIPT ‘TIME TO REMEMBER’ Interviewee: Mr Mark Moroney Date of birth: Place of birth: Interviewer: Roger Rawcliffe and Sue Lewis Recorded by: Roger Rawcliffe Date recorded: 16th November 2006 Topic(s): Being called to the English Bar Callow & Fick Finance Sector and UK taxes Furniss and Dawson Isle of Man Shelf Companies Issuing of Banking Licences Mr Brooks and misappropriation of client’s money Treat from UK over definition of ‘deemed domicile’ Legal profession and local practitioners Introduction of Land Speculation Tax Director of Savings & Investment Bank [SIB] Advocate Dicky Penn Training as Manx Advocate and exams Fo Halloo and Judah Binstock Increasing numbers of advocates and accountants Mark Moroney - Mr M Roger Rawcliffe - RR Sue Lewis - SL 1 Manx Heritage Foundation: TIME TO REMEMBER: Mark Moroney RR … writing a book on the history of the finance sector. It isn’t really – it’s not like Mark Solly’s book … Mr M Yes. RR ... which has got everything to be known about the finance sector … Mr M Yep. RR … repeated five times in different chapters. Mr M Yep. RR This is err … trying to give the round picture … Mr M Yes. RR ... it also involves … things like … Manx people complaining about the finance sector … Mr M Yes. RR ... you know, all the sort of issues … Mr M Yep. RR ... of building and cars and … Mr M Yes. RR It’s the whole picture. Err … I came – I was engaged – I came, first, in the 1940s here ... Mr M Yes. RR ... and I’ve been engaged to Elizabeth in 1969, and been coming regularly … Mr M Yes. 2 Manx Heritage Foundation: TIME TO REMEMBER: Mark Moroney RR ... so a lot of it took place … Mr M Yes. RR ... and I knew it was taking place, and I knew some of the things … Mr M Yea. RR ... but I only came here at the end of 1979, so the bit between 1960 and 1980… Mr M Yes, yes. RR ... I don’t really know directly. Mr M Yes. RR Umm … when did you start? Mr M I came … umm … I came to the Island in 1970 ... umm ... I … RR Your parents came, didn’t they? Mr M No, I came – they came after me, I came on my own … RR Yea. Mr M ... in 1970, I’d umm … I’d been to Oxford, I taught at university for a year in Liverpool … RR Yes I know, yes. Mr M ... and then I got called to the English Bar and did a pupillage and then came over here, qualified for two years, and umm … RR Who did you qualify with? Mr M Oh, with Mr Crellin – Mr John Crellin. 3 Manx Heritage Foundation: TIME TO REMEMBER: Mark Moroney RR Oh, were you? Right, were you – could be illuminating, yes! (laughter) That’s what – I’m going to have to see him, but that’s one of the areas which could be very interesting. Mr M Yes, umm … the umm … the – I … I set up in … Colin Fick was in …was in the partnership, so I joined him in 1972. RR So, 1972 … I remember … Mr M Yes. RR Callow & Fick, wasn’t it? Mr M That’s right, yes, yes, ‘cos Henry Callow became the High Bailiff … RR He’d become ...? Mr M High Bailiff. RR High Bailiff. Mr M Yea, yea. RR So you … 1972 … I was hoping to talk … to Bill [tapping sound] Dawson … Mr M Dawson, yea. RR ... who came in 1969 … Mr M Humm. RR ... and the sort of general feeling I get – I never knew really when financial sector type of work started, but it seems only to have been in about 1972. Mr M It was the – it was very strange, when I first came here, there was ... umm a completely different attitude to what there is now to the Inland Revenue. Umm … 4 Manx Heritage Foundation: TIME TO REMEMBER: Mark Moroney RR Oh I know. Mr M ... people used to say that … umm … you know, that they had no reason for enforcement, and of course, you had a lot of people leaving England, because … because of the very high taxes, because, you remember, the end of the Labour Government, it was getting up with a surcharge to over 107%. RR 103 was the worse. Mr M Yes, they had a surcharge … RR 103 was the worse. Mr M That’s right – 103, ‘cos they had a 98% top rate, and then had a … RR Plus five. Mr M ... and then had a surcharge on it. RR Yes, Mr Jenkins had [unclear]. Mr M That’s right so (laughter) you know … RR 1968 that was (laughter) ... that was severe. Mr M The other point of course to umm … umm … to … to remember, is, of course, there was ... umm exchange control, so people … RR Absolutely. Mr M ... didn’t have the choice of movement. Umm … and the other thing which struck me at the time was, there was a tremendous umm … whereas nowadays everyone works with London, the things were very much with the Northwest. Manchester, Liverpool … RR Hmm. Mr M ... families from the Northwest coming here. 5 Manx Heritage Foundation: TIME TO REMEMBER: Mark Moroney RR I think it is still partly true, isn’t it, you know. Mr M It is, it is. RR We tend to have more contact there … Mr M It is, it is. RR ... though when I joined Pannells … Mr M Yes. RR ... we did a lot of work with Londoners – more work with Londoners. Mr M The other thing, Roger, which happened really – started at that stage and really happened up to the Furniss ... [Someone knocks and enters the room and then leaves] Mr M ... up to the Furniss and Dawson period … RR Hmm, hmm. Mr M ... was umm … there were an awful lot of these share exchange agreements and life settlements and reversions umm … tax schemes, ‘cos I remember, in Furniss and Dawson, I was an articled clerk and Mr Crellin asked me to go over and made me a director – you know, I was a director and went over to do the settlement, in nineteen … RR Was Furniss and Dawson set up in your time then? Mr M Oh yes. RR Is that one of John Crellin’s [unclear]. Mr M Yes, yes, it’s a – there’s a House of Lords Report on it. RR ‘Cos he was very much a pioneer. 6 Manx Heritage Foundation: TIME TO REMEMBER: Mark Moroney Mr M He was, he was, he was, he was John, yea. I mean, he – I mean, one of the things which used to actually happen was this roll-over share exchange scheme for capital gains. John, John did a lot of those … umm … I mean, I wasn’t there for long, but umm, and really, I ... I was asked to go as … as … as a student to be a director to do the completion, you know, but umm … RR We didn’t really – Pannells was not really into all that … Mr M No. RR ... very much, I mean, we started doing auditing and things. (laughter) But there were quite a lot of things that … like some of the ones we came across … Mr M Yes. RR ... where people set things for – which were not constructed … Mr M No. RR ... in a way which would stand [unclear], which were just for concealment. Mr M Well, it’s very difficult … RR There was more of that about … Mr M ... it’s very difficult, it’s very difficult, you know, to … to … I mean, one of the difficulties, it’s very difficult to know sort of looking back, you know, umm… umm, that umm … you know, but you know, but certainly that was end to it. You know, those sort of umm … tax schemes were … were part of the scene in those days. RR And what’s … that was even during the time when you were being articled? Mr M Well, the fact is that, in the Furniss and Dawson thing, the actual completion took place … the only reason I was there ‘cos I was a student, and was asked to … John and Peter Crellin were the directors, and I was asked ... umm to go over and do the settlement that day, so … 7 Manx Heritage Foundation: TIME TO REMEMBER: Mark Moroney RR So that was … that was … Mr M That was ’71. RR ’71, wasn’t it. Mr M Yea. RR That’s … that’s earlier than Bill Dawson was saying … Mr M Yea. RR I think he was thinking more in the terms of unit trusts and things ... Mr M Oh yes, well I don’t think … RR ... also started around there somewhere … Mr M Humm. RR ... and one of the things I tried to get to, is the … the use of trusts and companies in the various scheme that put up – some better than others – Furniss and Dawson was a very successful scheme. Mr M But I mean – it was alright for capital … capital … capital gains. I mean, I really, you know, can’t … I mean, I remember that these things were … that there were tax schemes about, but umm … you know … RR Anyway, I’m going to see John, and I’m going to see Dougie Bolton. Mr M Yes, yes, that’s right, well again, they would be very excellent. RR They were. Mr M Yes. RR And … and … and umm … 8 Manx Heritage Foundation: TIME TO REMEMBER: Mark Moroney Mr M Yes.