In this article, David Small and Roddy Macleod look at the Inner House ruling in Murray Group Holdings Ltd v Revenue and Customs Commissioners, and earlier litigation between the parties, on whether employee remuneration trusts operated by a football club for its players generated taxable earnings subject to income tax and national insurance contributions. The authors discuss the Inner House's approach to HMRC's "redirection of earnings" argument, including its views on the players' side letters.

This article was first published in British Tax Review (B.T.R. 2016, 1, 27-38) and is reproduced here with the kind permission of W. Green, The Law Publishers.