Murray Group (Rangers) tax case - decision today?

[WalterWhite]

Has anybody actually looked at the actual judgement?

While the mainstream media seem to be portraying an HMRC victory I would point out the following facts from the judgement:

- contributions are tax deductible for the company
- loans to the employee are not taxable as income
- loans to the employee are deductible against IHT
- this is not deemed tax avoidance


Surely this is something Big Group can use?

[DotasScandal]

While the mainstream media seem to be portraying an HMRC victory (...)

As often, what we do not see happening is as interesting as what we do see happening.
In this case, I am missing the usual triumphant HMRC press release / flyer. Why?

When Judge Simler decided in their favour in the Rowe JR, the HMRC press release was out within a split second of the judgement.

[Tomandjerry]

As often, what we do not see happening is as interesting as what we do see happening.
In this case, I am missing the usual triumphant HMRC press release / flyer. Why?

When Judge Simler decided in their favour in the Rowe JR, the HMRC press release was out within a split second of the judgement.

Based on previous experience, what is to stop HMRC claiming this as supporting their case, issuing APNs then following up with Direct Recovery if you don't pay the APN?

In which case the ins and outs of the case are immaterial.

[centurian]

Based on previous experience, what is to stop HMRC claiming this as supporting their case, issuing APNs then following up with Direct Recovery if you don't pay the APN?

Simple answer - an appeal to the Supreme Court.

If there is no appeal, or the appeal is not granted, or the appeal is lost, then it becomes a "final judgement" - which is the trigger to allow them to issue FNs against similar schemes.

[DcoC]

Simple answer - an appeal to the Supreme Court.

If there is no appeal, or the appeal is not granted, or the appeal is lost, then it becomes a "final judgement" - which is the trigger to allow them to issue FNs against similar schemes.

Murray Group was a mess of companies under one umbrella. The only one left standing is Rangers, who are being managed by BDO

It is unclear if they have the desire to appeal. There is little left in the pot to cover their expenses, never mind a court case. HMRC have driven it to this stage, and only because they never won the case until now

[LandRover]

Murray Group was a mess of companies under one umbrella. The only one left standing is Rangers, who are being managed by BDO

It is unclear if they have the desire to appeal. There is little left in the pot to cover their expenses, never mind a court case. HMRC have driven it to this stage, and only because they never won the case until now

No appeal and this becomes very useful for hmrc, any similar schemes may be target of follower notices. Perhaps this was the aim of hmrc, as why keep going when they lost at ftt and then upper tribunal, they knew one decision in their favour would result in Murray group administrator having to fund an appeal, which is highly unlikely with no funds.

[StrengthInNumbers]

HMRC plays this game very well. Fight state is never easy.

[centurian]

No appeal and this becomes very useful for hmrc, any similar schemes may be target of follower notices. Perhaps this was the aim of hmrc, as why keep going when they lost at ftt and then upper tribunal, they knew one decision in their favour would result in Murray group administrator having to fund an appeal, which is highly unlikely with no funds.

I think this is straight out of their playbook. Go after a weaker target, get a binding judgement - unlikely to be appealed. Then use the elements of the judgement in their favour to go after slightly bigger targets, rinse and repeat.

[DonkeyRhubarb]

You need deep pockets to take on HMRC.

Or lots of little pockets.

We've raised a fighting fund of £0.5M, from our members, to fight them.

[Dylan]

The lack of victory press release at this stage is quite interesting, really hope they've shot themselves in the foot, would be so poetic to see the bullying tactics blow up in their face.