Glasgow Rangers appeal lost by HMRC... but the case continues
The former Glasgow Rangers Football Club sought to pay bonuses to its players through loaning money to them from a trust, avoiding the need to pay income tax or National Insurance contributions on the payments.
Facts of the case
- The club’s parent company set up an employee benefit trust (EBT)
- 108 ‘sub-trusts’ were established within the EBT for the benefit of the footballers’ families
- The club paid a total of £55.5m and €5.3m into the ‘sub-trusts’
- Each ‘sub-trust’ loaned money to the employee footballer. Loans were made without security for a term of ten years (which was expected to be renewable) and interest was payable at 1.5-2 per cent above the base rate
- In theory, the loan could remain outstanding until the employee’s death, when it would be a debt on the employee’s estate (and so reduce the inheritance tax charged). However, the loan would be repaid to the sub-trust set up for the employee’s family, and so their family would still receive the money…
Click on the link below to read the rest of the Gateley briefing.
Sign in or Register to continue reading this article
It's quick, easy and free!
It takes just 5 minutes to register. Answer a few simple questions and once completed you’ll have instant access.Register now
Why register to The Lawyer
In-depth, expert analysis into the stories behind the headlines from our leading team of journalists.
Identify the major players and business opportunities within a particular region through our series of free, special reports.
Receive your pick of The Lawyer's daily and weekly email newsletters, tailored by practice area, region and job function.
More relevant to you
To continue providing the best analysis, insight and news across the legal market we are collecting some information about who you are, what you do and where you work to improve The Lawyer and make it more relevant to you.
News from Gateley
News from The Lawyer
Briefings from Gateley
A heritable creditor is required to ‘take all reasonable steps to secure that the price at which all or any of the subjects are sold is the best that can be reasonably obtained’.
If defects appear in a building after completion, the developer or contractor may be liable to the owners of the building, in contract or negligence, for the cost of remedying that work.
Analysis from The Lawyer
The Law Society recently published guidance to assist solicitors draw up Shariah-compliant wills, causing outrage in some quarters. Gateley’s Haroon Rashid explains the facts.