RFC 2012 Plc (in liquidation) (formerly The Rangers
Football Club Plc) (Appellant) v Advocate General for
Scotland (Respondent) (Scotland) [2017] UKSC 45
The Supreme Court has ruled in favour of HM Revenue &
Customs (HMRC) in the long-running dispute over
the use of an employee benefit trust (EBT)
arrangement by the company which formerly owned Glasgow Rangers
Football Club (Rangers), before it entered into
liquidation in 2012. The dispute has commonly come to be known as
the "Big Tax Case".
Background
The essence of the arrangement was that Rangers paid monies into
the EBT and further into various sub-trusts for the benefit of
players and other senior figures within the club. Loans to the
total value of around £47m were then made out from the
sub-trusts to over 80 players and other staff between 2001 and
2010. The loans were never repaid.
