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February 14, 2012


John Barnett

Agree with a lot of what you say, although EBTs also cover a range of aggressiveness. Just putting money into an EBT and making a genuine loan wasn't aggressive. Dextra and Sempra cases both suggest that this was entirely justifiable. What was aggressive was (a) trying to get a corporation tax deduction as well (b) pretending something was a loan when it wasn't and (c) finding ways to cancel the loan without an income tax charge. If Rangers were doing any of the latter 3 then I'd agree with you entirely. If they were just making genuine loans then I think that they are justified in complaining that HMRC are continuing to take the point despite having two cases from the higher courts (Dextra and Sempra) against them.

Also agree with you that the seven to eight year fight should have been explained at the outset. But there are plenty of bad-advisers out there who were selling these things and it may not have been.

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