as a partial win, but as the FTT found there were cases in which Rangers misused the EBT scheme, they have not been given a clean bill of health. The fact that the FTT went out of their way to state Rangers were not co-operative and strung out the whole process being told paperwork had been "lost" etc, strikes me as censure for those involved at Rangers end of this process. HMRC are perfectly entitled to refuse a settlement figure if they feel they would get more going through the courts. I as a tax payer applaud this. I can't believe you are saying HMRC pursuing delinquent tax payers through the courts is "govt excess" -- quite the reverse! THe fact that Rangers didn't contest the "wee tax case" gave HMRC grounds to pursue the full value of this. THenon-payment of PAYE and NIC were further strikes against OldCo Rangers -- something conveniently forgotten in this faux-outrage against the tax-man. I still anticipate Oldco to be presented with a bill approaching, if not exceeding, the 10m plea bargain Oldco offered previously. Andthere's the prospect of an HMRC appeal -- after all the FTT is only the FIRST TIER tax tribunal. Plenty to play for yet... Actually HMRC have very narrow grounds to appeal. It can only be on a strict point of law and the fact that the two majority decisions were made by tax law experts, as opposed to the minority view by a tax accountant, means it will