HMRC granted permission to appeal Rangers tax case on use of EBTs

Rangers FC
Rangers: The oldco Ibrox club won the case at the First Tier Tax Tribunal last November.

HM Revenue and Customs (HMRC) has been granted permission to appeal the Rangers tax case it lost last year.

The tax authority confirmed it had been given the go-ahead in the case on Monday after applying for leave to appeal in December.

A three-person panel found by a majority of 2-1 that Rangers oldco, which was owned by Murray Group Holdings through a subsidiary at the time, was not liable to pay tax on its use of employee benefit trusts (EBTs) after it won the appeal "in principle".

HMRC argued the loans were being paid as remuneration to players, making them liable to income tax and National Insurance.

It had originally assessed that £46.2m was due in tax by Rangers oldco and several of former owner Sir David Murray's companies, but the tribunal concluded the final bill would be "substantially reduced" from that amount.

On Monday, a HMRC spokesman said the appeal and papers relating to it had now been lodged with the First Tier Tax Tribunal.

The appeal, which is expected to be before the Upper Tax Tribunal, is expected to be held later this year although no date has been fixed yet.

Rangers made payments on behalf of several players and directors through the 81 sub-trusts between 2001 and 2010.

Hearings in the case took place in Edinburgh towards the end of 2011 and concluded in January this year but the verdict was not delivered until November 20.

Rangers oldco was consigned to liquidation in June 2012 after it failed to exit administration via a company voluntary arrangement (CVA).

The club's assets, including Ibrox stadium and the Murray Park training complex, were sold to the Charles Green-led consortium in a £5.5m deal. Administrators Duff and Phelps had been appointed by owner Craig Whyte with the company up to £124m in debt.

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