HMRC have issued a commentary in their Spotlight series (see Spotlight 41) commenting on the impact of the decision in the Rangers case.

This confirms their view that the case has a wide application, covering in addition to Employee Benefit Trusts (EBTs) disguised remuneration paid through employer funded retirement benefit schemes (or EFRBs’s) or contractor loan schemes (a variation on EBTs).

This development is to be expected. It emphasises the importance for employers to review tax planning involving payments to third parties and consider whether the Rangers decision creates risks and exposures which may not have been identified and if so, how best to address them.

Pett, Franklin & Co. LLP are experts in employee share schemes, executive incentives and share valuation. To find out how we can help you or your client, please call 0121 281 5798 or email enquiries@pettfranklin.com.