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Markel Tax

13 Feb 2019

The final whistle: Rangers in the UK Supreme Court

Over the last ten years, many Glaswegian football fans have found themselves unexpectedly concerned with the obscure tangle of tax laws surrounding the treatment of remuneration paid to third parties, as the contentious litigation between Her Majesty’s Revenue and Customs (HMRC) and the former owners of Glasgow Rangers Football Club (Rangers) made its stately progress through the courts system.

On 5 July 2017, the UK Supreme Court handed down its judgment in the final stage of the case, bringing to a close the dispute over the tax treatment of payments made to an Employee Benefit Trust (EBT) structure on behalf of players and management.

The case had already had a catastrophic impact on the various companies that formed the Murray Group, the former owner of Rangers, all of which have now been liquidated, and had seen the club penalised by the Scottish Football Association and demoted from the Scottish Premier League. EBT structures have also been used by a number of employers within professional football and also more generally in the UK, which has meant that the case has been the focus of interest far beyond the community of football players, managers and supporters.

In his article The Final Whistle: Rangers in the UK Supreme Court Thomas Dalby reviews the final judgment for Global Sports Law and Taxation Reports (GSLTR) - The International Resource to the Taxation of Sportsmen and Sportswomen.


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