HMRC granted leave to appeal Rangers tax case decision

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Ibrox StadiumImage source, SNS Group
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The tax authority claims that Rangers' use of employee benefit trusts should be taxable

HM Revenue and Customs (HMRC) has been granted permission to appeal against a tax ruling over Rangers Football Club's use of employee benefit trusts (EBTs).

In July, an upper-tier tax tribunal (UTT) largely upheld a first-tier tribunal (FTT) decision, external that EBT payments made to players and other employees should not be taxable.

Rangers former owners, the Murray Group, argued the payments were loans.

HMRC's latest appeal will be heard at the Court of Session in Edinburgh.

HMRC's tax claims were mostly rejected at a first-tier tribunal (FTT), which issued a 2-1 majority verdict in November 2012 favouring, in principle, the Murray Group.

Consequently, HMRC's demands for £46.2m, about three-quarters of which related to Rangers, was substantially reduced.

The UTT largely upheld that verdict but ordered some payments to be re-examined by the original tribunal, including termination and "guaranteed bonus" payments.

The ongoing tax claim has no impact on the current Rangers owners.

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