HMRC Granted Leave to appeal Rangers Case

**flamel** · 9 March 2016, 14:49

Originally posted by Not Losing Any Sleep View Post

BDO allowed to appeal Rangers tax case to Supreme Court - BBC News

Hearing in London.

Rangers oldco liquidators given green light to appeal to Supreme Court over legality of EBTs - Daily Record

Title should have been "BDO allowed to appeal" - HMRC don't want an appeal to happen as they had just ~~bought off the judges~~ won their case

**StrengthInNumbers** · 9 March 2016, 15:13

And HMRC won in Supreme Court against UBS and DB Group today.

**flamel** · 9 March 2016, 15:51

The judgement has a great few opening lines

"In our society, a great deal of intellectual effort is devoted to tax avoidance.

The most sophisticated attempts of the Houdini taxpayer to escape from the manacles of tax (to borrow a phrase from the judgment .... in W T Ramsay Ltd v Inland Revenue Comrs ... generally take the form described in Barclays Mercantile Business Finance Ltd v Mawson:

“... structuring transactions in a form which will have the same or nearly the same economic effect as a taxable transaction but which it is hoped will fall outside the terms of the taxing statute. It is characteristic of these composite transactions that they will include elements which have been inserted without any business or commercial purpose but are intended to have the effect of removing the transaction from the scope of the charge.” ...."

HMRC Granted Leave to appeal Rangers Case