The Supreme Court has upheld the decision of the Scottish Court of Session in what has become known as the ‘Big Tax Case’.
The Court found that an employee benefit trust (“EBT”) scheme which redirected employees’ earnings by way of loans from a series of trusts was ineffective for avoiding income tax and NICs.
Background
The appeal was brought by the liquidators for RFC 2012 Plc (“RFC”), the former corporate owners of the Rangers FC. RFC itself went into administration in 2012 with and the club itself is already under new ownership.
RFC was involved in a tax avoidance scheme designed to remunerate employees of the club.
As part of this scheme, RFC would pay a lump sum to a principal trust and would recomm...
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