The outcome was the FTT ruled the EBT scheme was legal. The UTT upheld that decision. HMRC went back to court and challenged not the legality of EBTs but if they eliminated a tax burden at all. On this point HMRC won. The outcome is EBTs are legal, they just don't avoid tax. nobody has ever said that EBTs were illegal, ever, at all. The question was always whether the payments were income from employment in the hands of the players. The ftt was not ruling on the legality or otherwise. They were deciding, wrongly as it turns out, on the tax point.