The Upper Tribunal has now handed down the eagerly awaited judgment in HMRC v Murray Group Holdings and others, better known as ‘the Rangers case’. Robert Waterson and Adam Craggs review the lessons from the decision, which resulted in a loss for HMRC in its campaign against EBTs that it is likely to appeal.
On 8 July 2014 the Upper Tribunal (UT) handed down its eagerly awaited judgment in HMRC v Murray Group Holdings and others [2014] UKUT 0292 (TCC) which concerned an employee benefit trust (EBT) structure. Most readers will know this case as the ‘Rangers case’ since the facts relate to employees of the Scottish football club as it existed before its liquidation and recent purchase.
Before discussing the Rangers case in more detail it may...
