The liquidators of Rangers' old operating company have come to a £54million settlement with HMRC, 10 years after the oldco was declared insolvent.

The revenue service had initially claimed £94.4m, the bulk of which came from the use of employee benefit trusts (EBTs) to pay staff between 2001 and 2009.

Players, staff and directors had been given tax-free loans which HMRC contended were income and thus taxable, something which was upheld by the Court of Session in 2015. An appeal to the Supreme Court was unanimously thrown out.

The revenue service had been claiming £47m for that alone, as well as a sum in the region of £10m relating to former owner Craig Whyte's failure to pay VAT and PAYE.

The total debts claimed when the former Rangers operating company were declared insolvent were in excess of £160m.

The agreement with HMRC means unsecured creditors will be paid 14.3p for every pound owed.

A letter signed by joint-liquidators James Stephen and Malcolm Cohen said: "We are pleased to advise that since the last report, we continued extensive and collaborative discussions with HMRC to reach a negotiated resolution in relation to the remaining elements of the claim.

"After significant input from BDO’s Tax Dispute Resolution team, together with our legal advisors, we were able to reach a composite settlement of £56m for the whole of the HMRC claim.

"Formal settlement documentation will ensure that HMRC will not raise any further claims in the liquidation.

"The agreed settlement with HMRC reflects the outcome of the Supreme Court decision in 2017.

"This composite settlement represents an agreed reduction to HMRC’s initial submitted claim in the liquidation.

"As a result, all other unsecured creditors should receive dividends totalling approximately 5.3p in the £ more than they would have otherwise received.

"It also negates the need for further protracted litigation which could have been costly to the liquidation estate.

"The Joint Liquidators have been in consultation with the Committee and it was agreed that the composite settlement of £56m was a positive outcome for the creditors."

An HMRC spokesperson said: “The Supreme Court ruled in HMRC’s favour in the case against Rangers’ tax avoidance scheme.

“We are pleased to have reached a settlement with the liquidators to recover the money due as a result of this judgment.”


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