FTT Verdict, Trust payments construed as earnings


An anonymised version of the First Tier Tribunal verdict was published by the Finance and Trbunals service today.  The 145 page document will take some reading but it concluded:

“the trust payments are to be construed as ‘emoluments’ for the purposes of the tax legislation”

For those without a dictionary to hand,… Emoluments: Synonyms earnings, pay, recompense.

I for one am absolutely shocked that Sir David’s confidence was misplaced on this matter.

Enjoy the game!

“having ascertained the real nature of the transaction, you cannot … disguise it by using camouflaged clothing”


‘it is wrong and an unnecessary self-limitation’ not to give regard to ‘the manifested intentions of the parties’ in the face of documents or transactions that are not ‘shams’

Orders are now open for the very first CQN Annual, get it here!

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  1. Gerry, They have lost, but have won “an appeal” typical MSM horseshit reporting………….

  2. tom thanks what pub will you be in?



    Loans were made by a trust not RFC. Up to them re repayments not BDO, no?



    Majority verdict is interesting

  3. Fantastic to watch the fans having a kick about on the hallowed turf of the Estadio National.



    On the FTT findings, surely the side letters put paid to the claim payments were loans.

  4. James Forrest is Neil Lennon! We are ALL Neil Lennon! on

    Rangers have certainly won the Big Tax Case.



    Paul’s quote above actually comes from the “dissenting opinion.”



    There you have it. They died for nothing.

  5. Awe_Naw_No_Annoni_Oan_Anaw_Noo on

    HMRC have the chance to recoup some of the lost income. The creditors not. Moonbeams and bankers protected. The MSM are due a good year with exclusives. There will be one a week soon as the EBT beneficiaries start to squeal. Whether the football authorities are interested in non employees of Rangers and actually employed by other clubs and associations receiving loans should be interesting.



    Radio Scotland leading with Rangers winning their tax appeal.



    It sets a precedent that will please UEFA and by extension the FFP guidelines. I.e no future worries about tax and EBTs used in the EPL.



    Will HMRC reappeal as they stated that they will ?



    Moonbeams never backed the SNP for nothing.




  6. In some respects absolutely delicious. sound like Minty was duped after all but by his own self-doubt. Sold the club to Our Hero for a quid and then Craigie boy did for them.


    I would now hope that BDO will go after these loans to get them recovered and fix some of the oldco creditors debts.


    Beautiful which ever way you look at it cos they are no more…..

  7. The fact is if RFC 1872-2012 had set aside a reasonable sum a couple of years ago to cope with what now turns out to be a manageable bill, they would still be alive



    Instead, they got liquidated for no reason




  8. So Mark Daly won a Bafta,


    RTC won the Orwell Prize,



    ….but Paul Baxendale-Walker was right all along???

  9. If that is the case JF, all players were reg’d legally…



    Funnee how fings turn out.



    So the claim that CW crashed the bus gains credence.



    I think???

  10. Rangers are insolvent ..dead



    Who cares what happens to a tax case involving a former club …



    The only implications of relevance are the dual contracts …

  11. makes no difference with the SFA/SPL issue the individual players did not have all their earnings registered with the football authorities.


    They have not been properly registered all games reversed to a 3-0 result and withdraw titles.


    The players not the deid club will have to pay the Tax and NI

  12. wonder also how many tax tribunals so far have delivered a majority decision? Have to say I found that one strange. Always thought tax matters , to the experts at least, would be black and white.

  13. oh timing, timing…






    We’re the famous Glasgow Celtic and we’re off to Wemb e ley……

  14. This does not look good:



    HMRC on Rangers tax case


    “We are disappointed that we have lost this stage of the court process and we are considering an appeal.



    “The decision was not unanimous and the diligence of HMRC investigators was acknowledged by the whole tribunal.



    “HMRC is committed to tackling avoidance and it is right that we challenge the type of avoidance seen in this case.”

  15. James Forrest is Neil Lennon! We are ALL Neil Lennon! on




    Not what I said mate lol. MIH and Rangers “won” the tax case, but the evidence in those findings relating to dual contracts is pretty much overwhelming.



    I expect there to be Hell to pay for that.

  16. Seems like Minty sold the Huns for £1 because of a tax liability that isn’t payable



    I find that very satisfying

  17. Awe_Naw_No_Annoni_Oan_Anaw_Noo on

    I wonder how many self employed Scots will now wholeheartedly embrace EBT payment methods now ?




  18. eternaloptimist on

    I’ve a funny feeling that second contracts will be popping up all over the place now, the fat lady aint singing yet

  19. Sir Paul



    Surprised at you.



    Pertinent tae the TTC Verdict…




    Ye know whit Dom .. used tae say..



    ” Sava da Applausa… Till .. Da End!”




    Translated fur the Non Initiated..



    Save yer Statement…until, it’s OFFICIAL..



    Maks.. sense . tae Me.




  20. Rangers Tax Result Para 161 p38:



    Side-letters, of course, had not been registered with the football authorities, the SFA and SPL. The spirit of their rules was that the whole contract terms should be registered. Suspiciously, no evidence was led as to who decided that the benefits in terms of the side-letters should not be registered. Non-registration of side-letters was incompatible with both authorities’ policing and disciplinary powers. For example any fines imposed on players would customarily reflect the disclosed wage. Non- disclosure would thwart the authorities’ powers.

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