Supreme Court finds for HMRC in Rangers EBT case

Supreme Court finds for HMRC in Rangers EBT case

The case considered whether amounts paid to an EBT by an employer for the benefit of an employee were taxable on the employee as earnings.


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The Supreme Court, in a unanimous decision, has dismissed the taxpayer’s appeal in what became known as the ‘big tax case’. This judgment brings to a conclusion a number of years of litigation around Employee Benefit Trusts (EBTs) and ‘disguised remuneration’. While it is of direct relevance to employers who have funded EBTs or Employer-Financed Retirement Benefits Scheme (EFRBS), the breadth of the conclusion may also impact more mainstream arrangements such as salary sacrifice and flexible benefits.

To read our full analysis of this case, click here.

For further information please contact:

Colin Ben-Nathan

Seamus Murphy

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