Shedding light on EBTs

Thursday 24 May 2012

l WHAT ARE EMPLOYEE BENEFIT TRUSTS (EBTS)?

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Also known as employee remuneration trusts, they were common practice in UK football, particularly the English Premiership, from the mid-1990s onwards. Money was paid into the offshore trusts and then loaned back to the players, with no expectation of them paying any interest. The scheme allowed tax and national insurance bills to be avoided.

l ARE THEY ILLEGAL?Although not illegal, Her Majesty's Revenue and Customs (HMRC) has been keen to close the loophole and recover funds, and began targeting football clubs several years ago. Between 2001 and 2009, Rangers are thought to have paid £46 million into remuneration trusts, coinciding with a time when the club was spending significantly on high-profile players. l WHO GAINED FROM THEM?Mainly footballers earning more than £6000 a week, but also club officials.l HOW MUCH DID RANGERS PAY INTO ITS EBT?The Ibrox club paid in £47.65m into their EBT between 2001 and 2010. l WHY ARE THE TRUSTS CAUSING RANGERS SO MANY PROBLEMS WITH THE TAXMAN.Payments from an EBT should not form part of a contract - as it would leave an employee subject to tax and National Insurance. HMRC argues the Ibrox scheme was contractual and it forms part of the so-called Big Tax Case.

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Shedding light on EBTs

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