HM Revenue and Customs is looking to appeal the verdict of the big tax case against Rangers.
A three-person panel found by a majority of 2-1 that Rangers oldco, owned by Murray Group Holdings through a subsidiary at the time, was not liable to pay tax on its use of employee benefit trusts (EBTs) after it won the appeal "in principle".
HMRC argued the loans were being paid as remuneration to players, making them liable to income tax and National Insurance.
The tribunal ruled, however, that the majority of payments were loans recoverable by the trusts, therefore not liable for tax. It noted: "It was conceded that advances in favour of certain players are taxable and liable to NIC, and we have found that in certain other limited instances, there may be a similar liability. To that extent the assessments should stand."
On Tuesday, a spokesman for HMRC said: "HMRC will seek permission to appeal the tribunal decision."
The tax authority is seeking permission from the Tribunals Service to appeal the decision at the Upper Tribunal.
HMRC had originally assessed that £46.2m was due in tax by Rangers oldco and several of former owner Sir David Murray's companies, but the tribunal concluded the final bill would be "substantially reduced" from that amount.
Rangers made payments on behalf of several players and directors through the 81 sub-trusts between 2001 and 2010.
Hearings in the case took place towards the end of 2011 and concluded in January this year but the verdict was not delivered until November 20.
Rangers oldco was consigned to liquidation in June after it failed to exit administration via a company voluntary arrangement (CVA).
The club's assets, including Ibrox stadium and the Murray Park training complex, were sold to the Charles Green-led consortium in a £5.5m deal. Administrators Duff and Phelps had been appointed by owner Craig Whyte with the company up to £124m in debt.
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