15 November 2017

Directors Duties: FAF Holdings v. Bethune

Christchurch entrepreneur Richard Bethune was ordered to pay tax arrears of $538,200 after washing staff tax costs for bar and restaurant Town Ball through related company FAF Holdings and then hanging FAF out to dry, insolvent.
Mr Bethune generated publicity for Town Ball using a giant inflatable rugby ball purchased from Tourism New Zealand to mark his Christchurch bar and restaurant.  After stopping trading in June 2014, Town Ball cleared off its major debts except liabilities to FAF Holdings another Bethune company responsible for Town Ball’s staff tax costs.
Mr Bethune operated the Boogie Nights and Shooters bars briefly for three months before the second major Christchurch earthquake in 2011 forced their closure.  Eleven months later he set up a new venture: Town Ball bar and restaurant.  The High Court was told a related company FAF Holdings Ltd was used to manage staff costs for Town Ball.  FAF was responsible for Town Ball’s staff wages, PAYE, Kiwisaver deductions and student loan obligations.  Town Ball was invoiced weekly.  Town Ball claimed a GST credit for the cost of FAF’s services.  The intent was for FAF Holdings to be tax neutral: money in from Town Ball would meet all its tax liabilities.  Evidence was given that Town Ball’s operating losses caused FAF to stop full invoicing, improving Town Ball’s liquidity but leaving a mounting unpaid tax debt with FAF.  When FAF Holdings was wound up insolvent by Inland Revenue in December 2014, Mr Bethune as director denied all knowledge of its deteriorating tax position.  An employee had hidden the true position he said.  Justice Woodhouse held Mr Bethune liable for breach of his duties as director of FAF: failing to act in good faith and trading recklessly.  He dismissed Mr Bethune’s claim to have no knowledge of FAF’s deteriorating financial position.  Mr Bethune monitored the cash flows of both Town Ball and FAF.  Mr Bethune improperly preferred the interests of Town Ball over that of FAF, Justice Woodhouse ruled.  Mr Bethune had personally guaranteed Town Ball’s lease and its banking accommodation.  Continuing to trade FAF Holdings for nearly eighteen months with its escalating unpaid tax debt amounted to reckless trading.  As director of FAF he did not force payment by Town Ball of its weekly staff costs.  He was in a position to cancel the management contract with Town Ball in order to limit FAF’s liabilities, but did not.  This amounted to washing Town Ball’s ongoing tax obligations into FAF.  Mr Bethune was held personally liable to compensate FAF Holdings for its unpaid tax bill.        
FAF Holdings Ltd v. Bethune – High Court (15.11.17)

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