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They think it’s all over

What next for HMRC following their loss in the Glasgow Rangers case?


  • 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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