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Ruling due on trust payments

Rangers ‘Big tax case’ verdict expected from Court

IbroxBDO, liquidators of the ‘oldco’ Rangers Football Club expect to hear today whether they have succeeded in their attempt to overturn a court ruling on almost £50 million paid to players.

The Supreme Court in London will rule on whether the Court of Session in Edinburgh made a correct call when it judged that £47.65m paid in ‘loans’ to more than 80 players and staff in employee benefit trusts (EBTs) were disguised wages.

The payments were made between 2001 and 2010 and the court judged that they should be subject to tax.

The seven-year saga, commonly known as the ‘Big Tax Case’, has has now reached the highest appeal court in the UK.

That decision related to the Murray Group companies, including the liquidated Rangers holding company RFC 2012 plc, and does not affect the current regime at Ibrox.

Among those who benefited from the scheme were Barry Ferguson – who received £2.5m, and might have to repay £1m. Dutch player Ronald de Boer may have to forfeit £500,000 and former manager Alex McLeish faces a potential liability of £680,000.

Sir David Murray, the club’s former owner, who received £6.3m through the EBTs, could be forced to pay back £2.5m.

The HMRC argued hat while EBTs are a legitimate vehicle they were misused from the late 1990s until tax legislation was tightened in 2010.

In court yesterday Andrew Thornhill QC, representing BDO, said the Court of Session had erred in law in their ruling and that the payments should not be liable to tax.


A verdict is expected today.


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