RFC 2012 Plc ((in Liquidation)) (formerly The Rangers Football Club Plc) v Advocate General for Scotland
Jurisdiction | Scotland |
Judge | Lord Hodge,Lord Neuberger,Lady Hale,Lord Reed,Lord Carnwath |
Judgment Date | 05 July 2017 |
Neutral Citation | [2017] UKSC 45 |
Court | Supreme Court (Scotland) |
Docket Number | No 2 |
Date | 05 July 2017 |
-
- This document is available in original version only for vLex customers
View this document and try vLex for 7 days - TRY VLEX
- This document is available in original version only for vLex customers
70 cases
-
Bluecrest v HMRC
...more case law (the decisions of the Supreme Court in RFC 2012 plc (formerly the Rangers Football Club) v Advocate General for Scotland [2017] UKSC 45, [2017] 1 WLR 2767 (“ Rangers”), and the decision of the Privy Council in the New Zealand case of Hadlee v Commissioner of Inland Revenue [......
-
Winstanley (as personal representative of Winstanley deceased)
...the phrase used by Lord Hodge JSC in RFC 2012 plc (in liquidation) (formerly Rangers Football Club plc) v Advocate General for Scotland [2017] BTC 22 where he said at The legislative code for the taxation of income has developed over time to reflect changing governmental policies in relatio......
-
Strategic Branding Ltd
...Wilson under the principles set out in RFC 2012 plc (in liquidation) (formerly Rangers Football Club plc) v Advocate General for Scotland [2017] BTC 22). [56] It is for HMRC to establish, on the balance of probabilities, that the discovery assessments were valid. Strategic Branding has the ......
-
Charman v Revenue and Customs Commissioners
...Customs Comrs [2019] UKSC 19; [2019] 1 WLR 2754; [2019] 4 All ER 127; [2019] STC 926, SC(E)RFC 2012 plc v Advocate General for Scotland [2017] UKSC 45; [2017] 1 WLR 2767; [2017] 4 All ER 654; [2017] STC 1556, SC(Sc)Tennant v Smith [1892] AC 150, HL(Sc)UBS AG v Revenue and Customs Comrs [201......
Request a trial to view additional results
6 firm's commentaries
-
Glasgow Rangers The 'Big Tax Case'
...2012 Plc (in liquidation) (formerly The Rangers Football Club Plc) (Appellant) v Advocate General for Scotland (Respondent) (Scotland) [2017] UKSC 45 The Supreme Court has ruled in favour of HM Revenue & Customs (HMRC) in the long-running dispute over the use of an employee benefit trus......
-
HMRC Is Taking Action After The Rangers EBT Ruling: Issues Facing Trustees
...2012 Plc (in liquidation) (formerly The Rangers Football Club Plc) (Appellant) v Advocate General for Scotland (Respondent) (Scotland) [2017] UKSC 45 (the Rangers Case), HMRC have already begun to issue enforcement notices to sponsoring employers for the payment of tax and National Insuranc......
-
Strategic Decision: Remuneration Trusts
...in Part 7A of ITEPA; and also a remuneration trust that led to the ground-breaking Supreme Court decision in the Rangers case [2017] UKSC 45 showing that those same rules were to a large degree The main issues in remuneration trusts are, naturally, whether the company gets tax relief for th......
-
Directors may be entitled to a refund of payments made in settlement of the HMRC loan charge
...on payments into the EBTs. Following lengthy and unsuccessful challenges by employers to the APNs and Notices (see, the Rangers FC case, [2017] UKSC 45) HMRC could pursue employers for unpaid tax. However, HMRC had no recourse against the employees who had receiving the benefit of payments ......
Request a trial to view additional results
1 books & journal articles
-
Comment on the decision in RFC 2012 Plc (in liquidation) v Advocate General for Scotland [2017] UKSC 45
...of Southampton Student Law Review Vol.8 Comment on the decision in RFC 2012 Plc (in liquidation) v Advocate General for Scotland [2017] UKSC 45 Markos Phillips University of Southampton Abstract n the Rangers1case, the Supreme Court heard an appeal concerning whether a charge to income tax ......