HM Revenue and Customs is to appeal the outcome of a tribunal that saw the former Rangers Football Club win its tax case.
Last month oldco Rangers won its appeal in principle against a bill from HMRC over its use of Employment Benefit Trusts (EBTs) from 2001 to 2010.
The tribunal stated the "controversial monies received by the employees were not paid to them as their absolute entitlement".
A spokesman for HMRC said: "HMRC will seek permission to appeal the tribunal decision."
Rangers said the payments, thought to be about £48million, were loans rather than wages and not subject to tax.
The oldco was consigned to liquidation in June after it failed to exit administration via a Company Voluntary Arrangement.
Parties need to apply to the tribunal to seek leave to appeal and HMRC has started that process, the spokesman said.
A First Tier Tax Tribunal heard Rangers' appeal over the EBT bill over 29 days and last sat in January.
Judges delivered a 2-1 majority verdict two weeks ago that allowed the appeal in principle and declared the assessments of HMRC be "reduced substantially".
Two of the judges decided only some of the payments made to players through EBTs were taxable but that many of them could be described as loans, as the club had argued.
Rangers was under the control of owner Sir David Murray when it began using EBTs. He sold the club for £1 to Craig Whyte in 2011.
Although no final figure was revealed in the 145-page verdict, Murray International Holdings, the former majority shareholder of the liquidated club, declared itself vindicated after being left with what it described as "minimal tax liability".
Meanwhile, BBC Scotland will not face action from broadcasting regulator Ofcom after it received 54 complaints over a BBC Sportscene programme in September that showed Rangers' manager Ally McCoist falling from Ibrox Stadium in a spoof suicide.
It sparked protests by Ibrox bosses and the BBC denied claims of bias in its reporting of the club. The BBC later revealed it received more than 270 complaints at its Glasgow headquarters about the programme.
Ofcom said it had decided not to launch an investigation into the broadcast and no further action would be taken.
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