IT was the legal timebomb that led to the downfall of one of Rangers' so-called "Big Tax Case" was seen as the catalyst for the disastrous eventual sale of the club to disgraced former owner
Yesterday upper tier tribunal judge
Sir David successfully argued the payment had been loans rather than wages and therefore not subject to tax.
Many believe the prospect of the EBT tax debt was the key to Rangers' financial difficulties, with
If the HMRC appeal had been successful, the debt would have been added to the millions left behind by the old club company RFC 2012 plc, with little effect on the newco company.
The ruling was seen as vindication for fans over the persistent allegation the club had effectively cheated its way to titles through the use of EBTs.
EBTs were commonly used to enable companies to minimise the income tax and
The concern over Rangers' tax liability grew when in
However, many of the previous tax advantages of that particular arrangement were removed as part of the 2011 Finance Act.
HMRC contends that EBTs were used by more than 5000 UK firms, including football clubs in
Football finance expert
"Losing the appeal doesn't help them. You could say that publicly it is more an embarrassment that they pursued this so aggressively and lost it, but they will say, rightly, it is taxpayers' money at the end of the day and if they think tax is due it is right that they pursue it," he said.
"But the fact they lost this one won't necessarily put them off the other ones because every case is slightly different."
"This was tax planning, which I think Rangers will admit themselves was at the aggressive end of the scale, but it has been found to be at the right side of legality."
In December, 2012, a panel found that the oldco, owned by
Three months later HMRC launched an appeal.
IT was the legal timebomb that led to the downfall of one of
Rangers' so-called "Big Tax Case" was seen as the catalyst for the disastrous eventual sale of the club to disgraced former owner