There's nothing new in this post, just pulling together all the points aready mentioned above. This is my understanding of the EBT tax issue.
1. The Chancellor has said that he WILL recover the income tax due. As far as I'm aware, HMRC will be looking for this tax whether BDO win the appeal or not. Whether the final sums will also include National Insurance, penalties and interest is possibly irrelevant for most recipients - even the base sums are going to beggar them.
2. Given how the trusts were set up and which company paid into them, I'm not sure which company the tax man will go after. But it doesn't really matter - they're all dead.
3. Assuming the loans are seen as coming from Rangers rather than from one of SDM's companies, the taxman might add his claim to the list of creditors being overseen by BDO but I suspect not - he's already going to be short-changed on the existing tax bill.
4. So, in these circumstances, the tax man has said he will go after the 'loan' recipients instead. Billy Doods, Tore Andre Flo et al can wave their indemnity letters in Hector's face but he's just going to shrug and say, 'the company can't so you'll just have to pay up'.
5. Next, I'd expect the recipients to turn to whoever guaranteed that they'd pay no tax and ask them to pay up. According to the side letters, that would appear to be The Rangers Football Club plc (RFC 2012 plc in liquidation). Even if BDO agreed that these were newly-identified creditors and added them to the list, I suspect HMRC would tell the loanees to GTF and pay up. Otherwise it would turn into an Alice-in-Wonderland scenario - 'We can't get the tax from the deadco so we're asking you, Mr Flo, and you're telling us you're passing the debt onto the liquidators of the very company that couldn't pay us in the first place.' Nah.
6. Next, the recipients will turn to RIFC/Rangers International plc as the spiritual sucessors to RFC 2012 plc. And that's when it gets interesting.
Can anyone pick it up from there? What are ins-and-outs of the club and company implications, footballing debts, keeping the good bits and shedding the bad bits, etc?