HM Revenue and Customs is to appeal against the outcome of a tribunal which 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 that the "controversial monies received by the employees were not paid to them as their absolute entitlement".
Today a spokesman for HMRC said it is appealing against the decision.
"HMRC will seek permission to appeal the tribunal decision."
Rangers argued that the payments, thought to be close to £49 million, 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.