Rangers loses EBT final: tax decision of the decade

In a groundbreaking decision, the Supreme Court ruling in the long-running Murray Group holdings case - the Rangers case - about the validity of the use of employment benefit trusts (EBT) to pay footballers has hit the wall as the judges rule that they are unacceptable. Peter Rayney FCA, CTA examines the decision and the consequences

Looking back every decade seems to throw up its landmark tax avoidance case. We had Ramsay ([1982] AC 300) in the eighties, the nineties gave us McGuckian ([1997] STC 908), and arguably the noughties produced Barclays Mercantile ([2004] UKHL 51). For my money, the Glasgow Rangers employee benefit trust (EBT) case (RFC 2012 plc ([2017] UKSC 45) will go down as the defining tax avoidance case of the current decade.

The Supreme Court judgment handed down on 5 July 2017 is highly significant since it deals with employee benefit trusts (EBTs). Over the past few decades or so EBTs and similar structures have been widely used by owner managed companies.

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