RFC 2012 PLC (In Liquidation) (Formerly the Rangers Football Club PLC) v Advocate General for Scotland: Discerning the Goal of the Legislation

Abstract

RFC 2012 plc (in liquidation) (formerly the Rangers Football Club plc) v Advocate General for Scotland (RFC 2012)1 is another judgment in which the Supreme Court seems to make tax avoidance cases appear easy to decide. Lord Hodge gives a judgment with which all other members of the court agree. He elucidates broad principles of construction which seem so general and obvious that no one would disagree. Yet the application of those principles seems suspect. The judgment is also unusual in that it signposts future avoidance strategies.

Keywords: Rangers, UKSC, Tax Avoidance

JEL Classification: K34, K31, H26