The Supreme Court has now ruled in HMRC’s favour, bringing to an end a long legal battle with Rangers football club over its use of Employee Benefit Trust (EBT) arrangements.

Any employers who have ongoing EBT or similar arrangements should urgently review how they can be resolved, as whilst the opportunity to settle with HMRC is understood to remain open at the time of writing, this may be expected to be closed quickly given their success in Rangers.

Those employers not settling with HMRC will in any event be faced with a PAYE and NIC liability on loans which remain outstanding on 5 April 2019 and so the longer term option of doing nothing is simply not available.

If you would like to discuss, or require assistance, please contact Andrew Wilson or Jon Kicks to discuss your options.