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Issue:
4462
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Categories:
Comment & Analysis
, Dextra Accessories
, EBTs
, Glasgow Rangers
, Sempra Metals
, Business
, Employees
, Income Tax
, Inheritance Tax
, Investments
, Venture capital
What next for HMRC following their loss in the Glasgow Rangers case?
KEY POINTS
- A brief refresher of the Glasgow Rangers case.
- Why do HMRC contest old cases after defeats in Dextra Accessories and Sempra Metals?
- Is ITEPA 2003 Part 7A being used retrospectively?
- The income tax and inheritance tax implications.
- HMRC should consider the tax advantages of their present position.
On 8 July 2014 the Upper Tribunal published its ruling in relation to Murray Group Holdings ([2014] UKUT 0292(TCC)) and its employee benefit trust (EBT) transactions.
Most of us know this as the Glasgow Rangers case and although some matters were referred back to the First-tier Tribunal the judges ruled again in favour of the taxpayer.
This article is not intended to be a technical analysis of the case but rather a look at “what now?” for...
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