HMRC have issued the latest tax avoidance spotlight, on EBTs, following the Supreme Court decision in RFC 2012 plc.

The 5 year battle between HMRC and Rangers Football Club, resulted in the Supreme Court decision, released on July 2017, to dismiss Rangers appeal.

The Supreme Court decided that the loan was a payment made in consideration of employment services provided and that it was a redirection of earnings and it did not remove the liability to tax and NIC.

Now, following the decision, HMRC have issued its latest Spotlight relating to tax avoidance schemes, Spotlight 41: Disguised remuneration: a Supreme Court decision.

Anyone who has used an EBT, EFRBS, or other scheme to try and disguise remuneration, should consider reviewing the Spotlight guidance as HMRC have suggested they will use this case in support of new Follower Notices and Accelerated Payment Notices.

It should be noted that any reference to Rangers above is not to the current company owning the football club, but to Rangers 2012 plc.


Spotlight 41: Disguised remuneration: a Supreme Court decision

Tax Avoidance Schemes

Disguised remuneration

Anti-avoidance: HMRC’s spotlights

Supreme Court dismisses Rangers EBT appeal

HMRC defeats another EBT scheme

Accelerated Payment Notices and Follower Notices

External link

HMRC spotlight

Case link:

RFC 2012 Plc (in liquidation) (formerly The Rangers Football Club Plc) v Advocate General for Scotland [2017] UKSC 45   


Wouldn’t it be great and think how much TIME it would SAVE you if someone:

  • READ all the latest tax news, case decisions, new legislation and articles in tax and then summarised them for you?
  • Only alerted you to things that are RELEVANT to you?

How about if that someone also:

  • Updated those summaries in REAL TIME for you
  • ADDED examples, planning points, toolkits and calculators, and
  • Linked all that information together and also provided you with CPD?

Thousands of firms of accountants and advisers are already using as their primary TAX resource.

At a cost of just £1 per day, it’s a no brainer: FREE up your MIND and your TIME (and your wallet).

And...we run our Virtual Tax Partner support service, if you need assistance with a particular query or technical issue.