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Rangers case still waiting Supreme Court decision on EBTs

With a final decision on the Rangers case still pending from the Supreme Court, an address by the Rt Hon Lord Drummond Young in February still has resonance for the tax profession. Mark Cawthron CTA LLB, specialist tax writer at Wolters Kluwer, went along to hear the arguments on redirection of income and the Ramsay principle in light of the Murray Group EBT case

The talk, The Rangers case: HMRC v Murray Group Holdings – Substance and form – the triumph of reality over language? was delivered at the Inner Temple, London, this spring, and the talk was of much interest, not least because the Supreme Court was fixed to hear the taxpayer’s appeal in the case in March.

Lord Drummond Young had of course given the judgment of the Court of Session in the Rangers case (Advocate General for Scotland v Murray Group Holdings Ltd [2015] BTC 36); he had also given the principal judgment in the important earlier case of Aberdeen Asset Management plc v R & C Commrs [2013] BTC 726.

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