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| Version 0 | Version 1 |
|---|---|
| HMRC bids to appeal Rangers tax case | HMRC bids to appeal Rangers tax case |
| (about 1 hour later) | |
| HM Revenue and Customs has announced that it has applied for permission to appeal a tax ruling over Rangers' use of employee benefit trusts (EBTs). | HM Revenue and Customs has announced that it has applied for permission to appeal a tax ruling over Rangers' use of employee benefit trusts (EBTs). |
| Last month, an upper-tier tax tribunal dismissed an HMRC appeal against a first-tier decision on payments made to players and other employees. | Last month, an upper-tier tax tribunal dismissed an HMRC appeal against a first-tier decision on payments made to players and other employees. |
| The tax authority argued unsuccessfully that the payments should be taxable. | The tax authority argued unsuccessfully that the payments should be taxable. |
| The Murray Group, which formerly owned Rangers, argued that the payments were loans. | The Murray Group, which formerly owned Rangers, argued that the payments were loans. |
| In a statement on Thursday, HMRC said it had applied for permission to appeal the case to the Court of Session. It must prove there is a basis for the appeal on a point of law. | |
| 'Important principle' | 'Important principle' |
| It said: "HMRC continues to believe that schemes using employee benefit trusts to avoid tax do not work. | It said: "HMRC continues to believe that schemes using employee benefit trusts to avoid tax do not work. |
| "Around 700 users of EBT schemes have already settled with us resulting in around £800m of tax and NICs (National Insurance Contributions) being paid. | "Around 700 users of EBT schemes have already settled with us resulting in around £800m of tax and NICs (National Insurance Contributions) being paid. |
| "We expect more to settle in the near future. | "We expect more to settle in the near future. |
| "These are avoidance schemes and we will continue to tackle those who do not pay up. | "These are avoidance schemes and we will continue to tackle those who do not pay up. |
| "It is not right that a small minority can avoid paying what they owe while the vast majority pay the right tax on their earnings. | "It is not right that a small minority can avoid paying what they owe while the vast majority pay the right tax on their earnings. |
| "This case represents an important principle." | "This case represents an important principle." |
| 'Proud of record' | 'Proud of record' |
| The statement added: "HMRC is proud of our record of winning around 80% of cases that are taken to litigation by the taxpayer. | The statement added: "HMRC is proud of our record of winning around 80% of cases that are taken to litigation by the taxpayer. |
| "We tackle avoidance wherever we see it and litigate where necessary to ensure schemes are defeated and the tax due is paid." | "We tackle avoidance wherever we see it and litigate where necessary to ensure schemes are defeated and the tax due is paid." |
| The first-tier tribunal (FTT) had issued a 2-1 majority verdict in November 2012 which favoured, in principle, the Murray Group and ordered that HMRC's £46.2m demands, about three-quarters of which referred to the liquidated club, be "reduced substantially". | The first-tier tribunal (FTT) had issued a 2-1 majority verdict in November 2012 which favoured, in principle, the Murray Group and ordered that HMRC's £46.2m demands, about three-quarters of which referred to the liquidated club, be "reduced substantially". |
| The upper-tier appeal largely upheld that verdict but some payments will be re-examined by the original tribunal, including termination and "guaranteed bonus" payments. | The upper-tier appeal largely upheld that verdict but some payments will be re-examined by the original tribunal, including termination and "guaranteed bonus" payments. |
| The tax case has no impact on the current Rangers owners. | The tax case has no impact on the current Rangers owners. |
| The Murray Group was unavailable for comment. |