![TC09660 - [2025] UKFTT 01226 (TC)](https://backend.juristeca.com/files/emisores/logo_7HSuEAV.png){kind=logo}
The effect of the decision in RFC 2012 plc (formerly the Rangers Football Club plc) v Advocate General for Scotland [2017] UKSC 45 (“ Rangers ”) is that the payments made by the employer to the trust
The effect of the decision in RFC 2012 plc (formerly the Rangers Football Club plc) v Advocate General for Scotland [2017] UKSC 45 (“Rangers”) is that the payments made by the employer to the trust were Mr Brown’s redirected earnings and thus taxable as employment income at the point of that redirection irrespective of whether the loan was repaid or not. The amount of those redirected earnings is the amount of the loan the evidence for which is in the P11D form submitted by AML.
- Heading
- INTRODUCTION
- THE EVIDENCE AND THE FACTS
- DISCUSSION
- There is no justification for HMRC saying that the tribunal has no jurisdiction in relation to his appeal
- The Rangers decision was released after the tax year under consideration
- The loan was repaid and thus there is no liability to tax on it
- The effect of the decision in RFC 2012 plc (formerly the Rangers Football Club plc) v Advocate General for Scotland [2017] UKSC 45 (“ Rangers ”) is that the payments made by the employer to the trust
- The decision in Hoey v HMRC [2022] EWCA Civ 656 (“ Hoey ”) is authority for the proposition that this tribunal has no jurisdiction to consider HMRC’s discretion to impose any tax on Mr Brown rather th
- There is no justification in the complaints made about the statutory review process which was undertaken wholly properly The application of the loan charge legislation is not relevant to this appeal
- My view
- Conclusions