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Volume 6 No. 212


Scottish Third Division side Rangers FC "has won its appeal over a near £49M ($78M) tax bill for the use of Employee Benefit Trusts," according to the Scotland DAILY RECORD. The first tier tax tribunal, which heard the appeal Tuesday, "delivered a majority verdict, which ruled the EBT payments were loans that can be repaid." The club, which is now in liquidation, used EBTs from '01-10 "to make almost £49M in payments to players and staff in the form of tax-free loans." The club "had argued that the payments had been loans rather than wages and not subject to tax" (DAILY RECORD, 11/20). A statement from the three-person tribunal said: "The majority view reflects the argument that the controversial monies received by the employees were not paid to them as their absolute entitlement. The legal effect of the trust/loan structure is sufficient to preclude this. Thus the payments are loans, not earnings, and so are recoverable from the employee or his estate" (SCOTSMAN, 11/20).

RANGERS SATISFIED: The LONDON TIMES reported Murray International Holdings, "which was the majority shareholder of the oldco club until Craig Whyte's takeover in May '11," declared in a statement: "We are satisfied that the Tax Tribunal has now published its widely awaited decision and note the contents thereof." The decision "does not affect the current football club at Ibrox" (LONDON TIMES, 11/20). In London, Vanessa Houlder reported the judges did not reach a unanimous verdict, and Revenue & Customs said that it was "considering an appeal." In her dissenting opinion, Judge Heidi Poon ruled that payments from the trust should be construed as “emoluments” for the purposes of tax. She said there appeared to be a layer of “camouflaged clothing” over the real arrangements in the case (FINANCIAL TIMES, 11/20).

Foundation of Hearts "will go it alone" in its bid for control of Scottish Premier League club Heart of Midlothian FC, according to Barry Anderson of the SCOTSMAN. Foundation of Hearts Chair Alex Mackie stated that he "will not meet Angelo Massone or anyone else interested in buying out the Hearts Owner Vladimir Romanov." Mackie's consortium remains in "constructive dialogue" with Hearts Dir Sergejus Fedotovas -- Romanov’s right-hand man -- and is "currently preparing another bid after Romanov dismissed their £450,000 ($716,000) offer last week." Massone had his offer of £4.5M ($7.2M) rebuffed Monday and is "now keen to meet Mackie to see if they could work together." However, Mackie said, "We wouldn’t be meeting Mr. Massone, that would be a distraction we simply do not want at this stage. We will liaise directly with the owners ourselves. We’ve got so much going on just now, we don’t need that kind of distraction. I’ve said consistently that we still have a constructive dialogue with the owners and that is still the case" (SCOTSMAN, 11/20).

EPL Queens Park Rangers Manager Mark Hughes has told the club's board members that he will "not walk away from the club" after he was asked to resign as manager, according to James Olley of the STANDARD. Hughes met senior figures including QPR CEO Philip Beard and other "influential figures" in a meeting at which the Welshman was asked whether he would resign after just 10 months in charge. With the club willing to allow Hughes to depart, rumors "quickly circulated" Monday night that the 49-year-old had been sacked. However, once Hughes indicated he was not prepared to walk away, the club "stopped short of terminating his contract" without Chair Tony Fernandes in attendance. Hughes would be "entitled to pay-off in the region" of £5M ($8M) were the club to sack him, and Fernandes’ approval is required if that is to happen (STANDARD, 11/20).