HMRC has launched an appeal against a tax tribunal which found in favour of Rangers FC’s use of employee benefit trusts (EBTs).
The Revenue revealed its intentions to appeal the decision last December, when it started seeking leave to appeal.
Last year, the club won a case concerning its use of EBTs from 2001-2010, claiming the £49m in payments weren’t subject to tax as they weren’t wages.
Two out of three tribunal judges decided that only some of the payments were taxable, whereas many others could be seen as loans.
However, HMRC uphold that the scheme is illegal and the case will now be held at an upper tier tribunal.
If the case is not settled there, it will possibly be held in the Supreme Court.
In a statement, Rangers FC’s chief executive Charles Green said fans would be “disappointed” over HMRC’s decision to appeal.
“What the appeal does is cast a cloud of uncertainty and confusion over a situation that has already been ruled on and has taken a number of years to investigate,” the statement read.
“There is no money to be gained by HMRC as the oldco has been liquidated so you have to ask why they are pursuing the matter further, when the original EBT enquiry took years to reach a conclusion.”
Rangers also said it has written to HMRC to point out the “futility” of the appeal.
In May 2011, Craig Whyte bought the club for £1. Eight months later, Rangers was placed in administration after running up PAYE and VAT debts to HMRC.
In June, Rangers then went into liquidation after it emerged HMRC was owed £21m by the club. It was officially placed in liquidation in October.