Andrew Goldstone and Stuart Adams (Mishcon de Reya) provide the monthly update on the taxation of private clients.
Rangers: Supreme Court rules on EBTs
In RFC 2012 Plc (in liquidation) (formerly The Rangers Football Club Plc) v Advocate General for Scotland [2017] UKSC 45 Murray Group Management Ltd set up an employee benefit trust (EBT) in April 2001. 108 active sub-trusts were set up at various times between 2002 and 2008. The sub-trusts were funded from the head trust which in turn was funded by group employer Murray Group Holdings Limited (MGHL). In total the employer contributed funding of £55.5m and €5.3m into the sub-trusts. Each sub-trust was in the name of an individual employee and for the benefit of their family members. In almost all cases the full amount of the sub-trust funding was then lent to the employee.
HMRC assessed MGHL to...
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Andrew Goldstone and Stuart Adams (Mishcon de Reya) provide the monthly update on the taxation of private clients.
Rangers: Supreme Court rules on EBTs
In RFC 2012 Plc (in liquidation) (formerly The Rangers Football Club Plc) v Advocate General for Scotland [2017] UKSC 45 Murray Group Management Ltd set up an employee benefit trust (EBT) in April 2001. 108 active sub-trusts were set up at various times between 2002 and 2008. The sub-trusts were funded from the head trust which in turn was funded by group employer Murray Group Holdings Limited (MGHL). In total the employer contributed funding of £55.5m and €5.3m into the sub-trusts. Each sub-trust was in the name of an individual employee and for the benefit of their family members. In almost all cases the full amount of the sub-trust funding was then lent to the employee.
HMRC assessed MGHL to...
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