the ebt was being actioned. they didn't for reasons unknown to us. secondly your understanding of how an ebt works seems not to agree with the usually accepted version. an ebt is a Trust set up by an employer to make LOANS to their employees. the definition of a loan is that it has to be repaid. there are legal tax advantages in ebt schemes. fine so far. you like me might wonder why a football employer would want to set up a loan scheme for their players. I think the answer is that he does not but certain people have advised him that here is a way to pay salaries instead of loans and therefore reap the aforementioned tax advantages. lets call this a FALSE EBT. the employee either does not pay tax on earnings passing through a false ebt or he does and the employer withholds it from hmrc. either way hmrc are denied the tax due. in celtics case they used a false ebt to pay the players salary purely so that they or the player or both could illegally avoid tax. if hmrc had not investigated several years later and extracted the required tax from celtic, they would have got away with it. to be fair ( if that is a suitable word in these circumstances) celtic did own up to hmrc, thereby initiating the investigation. however this was not a selfless and noble act by celtic. they saw what was coming down the track in