IT is no surprise that HMRC has decided to appeal the majority decision of the Special Tribunal that Rangers Employee Benefit Trust (EBT) dealings over a 10-year period were not in breach of taxation law ("HMRC appeals Rangers win", The Herald, December 5) .
Of course there is very little to be recovered from the oldco company now in liquidation, and the creditors' debts are not the responsibility of the newco club, which wants to retain nothing of the old Rangers except their history, titles and trophies.
But that is not the primary objective of the tax authorities. The Rangers situation was nothing more than a test case for HMRC, which has much bigger fish to fry. It is rumoured that several of the largest clubs in the English Premiership, all hugely more wealthy than Rangers, have also been using EBT schemes to pay their players and senior management substantial amounts of tax-free income by making discriminatory loans which they don't expect to be repaid. It is also possible that other large companies outwith football have also been using such schemes for years to provide directors and senior employees with tax-free income. The tax potentially recoverable from all these sources would be enormous compared with the Rangers figure of around £49m.
Bizarrely one of the two judges on the Special Tribunal justified his decision to find against HMRC by arguing that, since none of the loans had ever been repaid, that proved that they were indeed loans, not taxable emoluments. Such payments are in my view a serious abuse of the UK tax system, and an insult to most employees who have no option but to pay their full tax liabilities, usually deducted at source by their employers. I fully support HMRC's attempt to shut down the exploitation of this tax loophole, and I am surprised that successive governments have not closed it long ago.
Iain A D Mann,
7 Kelvin Court, Glasgow.
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