Ibrox Stadium, home of Glasgow Rangers Football Club
Ibrox Stadium, home of Rangers Football ClubReuters

HM Revenue and Customs (HMRC) has applied for permission to launch an appeal in a tax battle involving Scottish football club Rangers' use of employee benefit trusts.

HMRC had argued that the former giant of the Scottish Premier League, which suffered spectacular financial ignominy and was relegated to the lowest orders of Scottish football, should have its employee benefit trusts taxed. The revenue has demanded £46.2m in back pay.

But an upper-tier tax tribunal dismissed the case after the former owner of Rangers, the Murray Group, claimed certain disputed payments were loans.

The case, which has no impact on the current Rangers owners, was originally brought to light in November 2012. The tribunal voted that the funds HMRC was asking for should be "drastically reduced" on account of Rangers financial situation.

HMRC appealed this decision, but an upper-tier tax tribunal revoked the case in July 2014.

However, HMRC is doggedly pursuing the case as a matter of principle and has now applied for permission to appeal it with the Court of Session.

HMRC said in a statement that it "continues to believe that schemes using employee benefit trusts to avoid tax do not work".

"Around 700 users of EBT schemes have already settled with us resulting in around £800m of tax and NICs (National Insurance Contributions) being paid. We expect more to settle in the near future."

"These are avoidance schemes and we will continue to tackle those who do not pay up. It is not right that a small minority can avoid paying what they owe while the vast majority pay the right tax on their earnings.

"This case represents an important principle."

HMRC has an 80% win record in dispute hearings with taxpayers.