How Rangers lost employment benefit trust (EBT) case at Supreme Court

When the Supreme Court rejected the Rangers employee benefit trust argument, HMRC appeared to have been vindicated. Ray McCann CTA, partner at Joseph Hage Aaronson examines the implications of the ruling, the implications for companies who used EBTs and did not settle with HMRC when an amnesty was offered, and the use of abusive tax avoidance schemes

As was said, ‘…they think it’s all over, it is now!’ You did not need to read much of Lord Hodge’s judgment in the Supreme Court decision in the Rangers football club employment benefit trust (EBT) case (RFC 2012 Plc (in liquidation) (formerly The Rangers Football Club Plc) (Appellant) v Advocate General for Scotland (Respondent) (Scotland) [2017] UKSC 45) to see that extra time would not be required.

In fact, less than half way through the opening paragraph it was all over. Ronnie Macdonald, the now retired HMRC inspector, who fought what seemed at times a one-man effort to stem the excess of the EBT tax avoidance industry, will no doubt have felt vindicated that this EBT had been shown to be simply ‘a mechanism for cash’, as he was often heard to remark.

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