Rangers: HMRC loses appeal over ruling in Big Tax Case

Rangers FC A verdict delivered by the first-tier tribunal in November 2012 favoured, in principle, the position of the Murray Group, which formerly owned Rangers

HM Revenue and Customs has lost its appeal over Rangers' use of Employee Benefit Trusts (EBTs) - the so-called "Big Tax Case".

Upper tier tribunal judge Lord Doherty dismissed the appeal against a first-tier tax tribunal decision but referred several issues back to the panel.

The tax authority had argued that payments made to players and other employees should be taxable.

The Murray Group, which formerly owned Rangers, argued they were loans.

The first-tier tribunal (FTT) had issued a 2-1 majority verdict in November 2012 which favoured, in principle, the Murray Group and ordered that HMRC's £46.2m demands, about three-quarters of which referred to the liquidated club, be "reduced substantially".

The upper-tier appeal has largely upheld that verdict but some payments will be re-examined by the original tribunal, including termination and "guaranteed bonus" payments.

Start Quote

It is obvious that the much publicised existence of these proceedings overshadowed Rangers Football Club for many years and tarnished the external perception of its value”

End Quote Murray International Holdings

However, the Murray Group appeared to secure an additional victory relating to payments made to several people including former Ibrox chairman Sir David Murray, which it argued were not special cases.

The judgement, which has no impact on the current Rangers owners, reads: "The appeal is dismissed except in so far as it relates to the termination payments.

"I shall remit the case to the FTT with a direction to allow the taxpayers' appeals against the assessments relating to the payments to the sub-trusts of Sir David Murray, his sons, Mr McClelland and Mr MacMillan; to proceed as accords in relation to the termination payments, the payments in respect of guaranteed bonuses, and any related questions of grossing up.

"Standing my findings and my disposal, the remit should be to the FTT as originally constituted."

It is unclear how many termination payments were made but the FTT's decision referred to five "guaranteed bonus" payments.

In a statement, a spokesman for Murray International Holdings (MIH) expressed satisfaction with the ruling but said there were no winners.

He said: "We are pleased with the judgement which again leaves negligible tax liability and overwhelmingly supports the views collectively and consistently held by our advisers, legal counsel and MIH itself.

"We will therefore review the detailed content of the decision with our legal counsel and advisers to ascertain what action, if any, is now required by MIH.

"The decision substantially reduces HMRC's claim in the liquidation of the old Rangers Football Club.

'Expensive process'

"While we have been successful in both the FTT and UTT, there are, as we have stated previously, no victors.

"This has been an exceptionally long, difficult and expensive process involving not just the FTT and UTT but also several approaches to resolve the with senior HMRC officials on a commercially sensible basis for all parties which were rejected."

The spokesman said MIH had, at all times, recognised that the tax tribunal proceedings stemmed from arrangements put in place during its ownership.

They were introduced before legislative changes removed the tax efficiency of such arrangements from the end of 2010, he added.

But he said: "However, it is obvious that the much publicised existence of these proceedings overshadowed Rangers Football Club for many years and tarnished the external perception of its value.

"There can be little doubt that despite favourable legal opinion, potential acquirers were therefore dissuaded from pursuing their interest during a period in which we were marketing the sale of MIH's shareholding.

"The case has also stimulated extensive press and social media comment, discussion and speculation, a significant quantity of which has been ill informed."

The spokesman said it would have been "entirely inappropriate" for MIH to have highlighted "fundamental misunderstandings or contribute to this public debate" during the legal proceedings.

He added: "Notwithstanding all of this, it is abundantly clear that Rangers Football Club would not have gone into administration or liquidation had the purchaser fulfilled its contractual obligations and responsibilities.

"Similar to the resolution of the UTT appeal, we hope that the relevant authorities conclude their investigations and commence proceedings at the earliest opportunity."

A spokesman for HMRC said: "We are naturally disappointed with today's decision and are considering an appeal."

HMRC has one month to decide whether or not to seek permission to lodge an appeal with the Inner House of the Court of Session.

Rangers began using the EBT scheme while under the control of Sir David Murray.

He sold the club for £1 to Scottish businessman Craig Whyte in 2011, while the tax liability was in dispute.

Rangers were subsequently forced into administration by HMRC in February 2012, over non-payment of tax totalling about £14m, while under Mr Whyte's control.

HMRC subsequently rejected proposals for a creditors agreement that would have prevented Rangers from going into liquidation.

Rangers released a statement in response to the decision on their website.

It said: "Rangers Football Club Limited (the "Club") notes the findings of Lord Doherty in the HMRC case against Rangers Football Club plc (Oldco) and shares the views of many fans that so much of what later ensued at our club following the start of that investigation was avoidable.

"We are pleased to see the end of this sorry chapter in the history of Rangers FC, yet our greatest sympathy is with those who felt the pain of the last four years the most - our supporters.

"In spite of almost unrelenting attacks and setbacks they have never flinched from supporting their football club with all their energy and resolve.

"It is a matter for the authorities to explain their actions during this entire period that has seen the good name of Rangers severely damaged.

"Our focus is on rebuilding the football club and getting Rangers back to where we belong. That, in itself, will help right some of the wrongs our club and supporters have suffered over the last four years."

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Scotland Decides: SCOTLAND VOTES NO

  1. No 1,305,388
  2. Yes 1,102,788
After 24 of 32 counts Results in detail

Referendum Live

    05:21: 'Work with anyone'

    Nicola Sturgeon says she will work with "anyone in any way" to secure more powers for Scotland.

    Tweet using #indyref 05:20: Get involved

    Derek Morison tweets: #indyref I spent 4 hours handing out YES leaflets at 2 Glasgow polling stations... and I find it extremely difficult to believe those figures

    05:20: 'Changed forever'

    Deputy First Minister Nicola Sturgeon tells the BBC the projected result is "a deep personal and political disappointment" but argues that "the country has been changed forever".

    05:20: Moore welcome

    Former Scottish Secretary Michael Moore welcomes the projected referendum result, adding that "the establishment" in Scotland is the SNP Scottish government.

    05:19: 'Move forward together' Brian Taylor Political editor, Scotland

    Deputy First Minister Nicola Sturgeon says there is no endorsement of the status quo.

    She says there is plainly a huge appetite for change.

    An indication of the ultimate response of the SNP: that they have a significant role in pressing the demands for change.

    "Move forward together," says the Deputy First Minister. And she confirms her party will work with anyone to deliver substantial new powers for the Scottish Parliament.

    nicola sturgeon
    05:18: 'Status quo'

    Comedian and independence campaigner Hardeep Singh Kohli says he felt that the "Yes" campaign had to deal with "the establishment" including the media, Westminster and big business.

    He asks how the Better Together campaign will manage to deliver its promises. "Scotland has voted for the status quo," he says. "Scotland will get the status quo."

    05:17: Margin of victory John Curtice Professor of politics at Strathclyde University

    The BBC is predicting on the basis of 26 results declared so far that the "No" side are going to win the referendum with 55% of the vote while "Yes" will secure 45% of the vote.

    This margin of victory is some three points greater than that anticipated by the final opinion polls.

    05:17: BBC forecast

    The BBC forecast is that Scotland has voted "No" to independence, with 26 out of 32 local authority areas declared.


    Referendum result projected to reject independence.


    "No" wins by 44,442 to 39,762.

    That is 53% "No" to 47% "Yes".

    Total votes 84,262. Turnout 84.5%.

    05:08: Aberdeenshire count Steven Duff BBC Scotland reporter

    Aberdeenshire declaration estimate now 05:30. Could it be a crucial one?


    "No" wins by 47,247 to 34,402.

    That's 58% for "No" to 42% for "Yes".

    Total votes 81,716. Turnout 86%.

    05:07: Tears of joy Eleanor Bradford BBC Scotland Health Correspondent

    The first tears of joy here at Better Together HQ.

    05:07: Glasgow vote Brian Taylor Political editor, Scotland

    Lord Reid, the former Labour cabinet minister, says the vote for "Yes" is partly a protest against poverty.

    He argues that must be heeded. Adds to my argument that there will be a popular expectation of change.

    Not, it would appear, independence. But change.

    Supporters of the Union said that a No vote did not mean no change. People will expect delivery of that and, I would submit, will expect delivery in particular from the party whose leading figures most prominently drove that offer. Which is Labour.

    And that message re: expectations is, of course, emphasised by the vote in Glasgow. A significant win for "Yes".

    05:05: Yes family

    SNP MSP Richard Lyle celebrates a "Yes" win in North Lanarkshire with his daughter, Councillor Marina Lyle, son Vincent, and granddaughter Iona.

    North Lanarkshire
    05:04: Lanarkshire divides Brian Taylor Political editor, Scotland

    The north votes "Yes". The south votes "No". Again, that vote in North Lanarkshire adds to the pressure upon Labour in particular to deliver upon the promises lodged towards the close of the campaign.

    Not just constitutional change but that people's lives would be enhanced.


    "No" wins by 65,682 to 53,342.

    That's 55% for "No" and 45% for "Yes".

    Total votes 119,024. Turnout 86.1%.

    05:03: Scottish Borders vote John Curtice Professor of politics at Strathclyde University

    This border area in south of Scotland was not somewhere we expected "Yes" to do well and getting 33% of the vote means our expectation is wholly fulfilled.


    "No" wins by 49,016 to 47,072.

    That is 51% for "No" and 49% for "Yes".

    Total votes 96,173. Turnout 84.4%

    05:01: Yes chant

    "Yes" supporters chant "Glasgow votes Yes".

    Yes supporters

    "No" wins by 55,553 to 27,906.

    That's 67% for "No" and 33% for "Yes".

    Total votes 83,459. Turnout 87.4%.

    Tweet @bbcscotlandnews 04:59: Get involved

    Tom [Positive Lad] tweets: Glasgow was a LOT closer than anyone thought. Low turn out too. That's not good for SNP / YES. #indyref

    Felicity tweets: Why such a comparatively low turn-out in the city where it could have made such a difference? People terrified of their influence? #indyref

    04:58: Ingliston chat Andrew Black Political reporter, BBC Scotland

    The chat on the ground at Ingliston is that Alex Salmond isn't putting in an appearance at the national counting centre. However, "Yes" supporters here are feeling more upbeat after the Glasgow win.

    04:56: Before the heartbreak

    An upbeat Tommy Sheridan was sure on Sunday that the "Yes" campaign would triumph in the Scottish independence referendum.

    Tommy Sheridan Tommy Sheridan speaking on the BBC's Sunday Politics to presenter Andrew Neil

    He told BBC presenter of the Sunday Politics show, Andrew Neil, how confident he was.

    When Neil put it to him that his side was going to lose, former socialist MSP Mr Sheridan said: "You have got to be kidding, is this the face of someone who is looking to lose - we will win 60%-40%."

    04:55: Yes Glasgow Tim Reid Political correspondent, BBC News

    tweets: Glasgow votes a massive yes to independence


    "Yes" wins by 194,779 to 169,347.

    That's 53.5% for "Yes" and 46.5% for "No".

    Total votes 364,664. Turnout 75%.

    04:54: Scotland 'divided'

    Lib Dem MP and former Scottish Secretary Michael Moore tells the BBC that "Scotland is divided", adding: "We're going to have a job of work to get things healed afterwards".

    04:52: 'Yes' victory possible? James Cook Scotland Correspondent, BBC News

    tweets: Just asked very senior figure in yes campaign, "Can you still win?" The answer. "No." #indyref #Scotland

    04:52: Analysis Brian Taylor Political editor, Scotland

    Perth and Kinross is the patch of John Swinney, Annabel Ewing and Roseanna Cunningham of the SNP. They will be disappointed with that.

    04:51: 'High spirits' Andrew Black Political reporter, BBC Scotland

    The "No" camp at the Ingliston national counting centre is in very high spirits now.

    They've gathered out on a balcony just inside the front entrance, their cheers growing louder as each local authority is declared for the pro-Union side.


    "No" wins by 62,714 to 41,475.

    That's 60% for "No" and 40% for "Yes".

    Total votes 104,285. Turnout 86.9%


    "No" wins by 121,800 votes to 100,990.

    That's 55% for "No" and 45% for "Yes".

    Total votes 222,790. Turnout 85.3%.


    "Yes" wins by 115,783 to 110,922.

    That's 51.1% for "Yes" and 48.9% for "No".

    Total votes counted 226,883. Turnout 84.4%.

    04:46: South Ayrshire count Alasdair Lamont BBC Scotland

    Word that the declaration in Ayr is about 10 minutes away.

    04:45: Flurry of excitement Andrew Black Political reporter, BBC Scotland

    There was a flurry of excitement just then, as news of First Minister Alex Salmond's arrival at the Ingliston national count centre spread like wildfire through the media section.

    But it was not to be. We are expecting him to turn up at some point, though.

    04:43: 'Broken-hearted'

    Former Socialist MSP Tommy Sheridan, who has been campaigning for a "Yes" vote, told BBC Scotland: "It is not looking good to be honest. I am feeling almost broken-hearted.

    "I feel that the British establishment has mobilised the big guns, they have mobilised the bankers, they have mobilised the billionaires, they have mobilised the supermarkets, they have all been corralled into Number 10 and told to get out there and frighten people and I think that people have been frightened."

    tommy sheridan
    04:43: Vote share so far

    The percentage tally so far, with 17 out of 32 local authority areas declared, is 56% for "No" versus 44% for "Yes".

    04:42: Scottish Borders count Morag Kinniburgh BBC News Scotland

    Scottish Borders declaration is due in 10-15 minutes.


    "No" wins by 48,314 votes to 30,324.

    That's 61% for "No" and 39% for "Yes".

    Total votes 78,938. Turnout 90.9%.

    04:39: Inverclyde analysis Sally McNair Reporter, BBC Scotland

    Inverclyde was always going to be a close call. Labour MP Iain McKenzie said it could come down to a handful of votes: in the event it came down to 86 votes in favour of a "No" vote.

    The result was declared to a hushed crowd here. This was predicted to be a significant count. In a traditional Labour stronghold, which has seen the Labour vote slipping, could the "Yes" campaign persuade enough Labour voters to give Labour a bloody nose? And would the result here be mirrored across the country?

    Both sides say they fought hard for every last vote. The "Yes" campaign were very confident earlier in the week, even earlier in the evening. They are hugely disappointed but the SNP group leader on Inverclyde Council, Chris McEleny refused to be downcast. He said having come from so far behind at one stage in the long campaign, to finish up with 49.9% of the vote was a remarkable achievement.


    "No" wins by 41,690 to 24,287.

    That is 67% for "No" and 33% for "Yes".

    Total votes 66,021. Turnout 90.4%.

    04:35: Stirling count Reevel Alderson Home affairs correspondent, BBC Scotland

    Just 12 minutes after the Stirling result was declared, the Albert Halls are cleared of boxes, counters and campaigners. Click here for updates on Stirling.

    04:35: Recap

    Half of Scotland's local authorities have now declared their results.

    The pro-Union "No" campaign is currently in the lead.


    "No" wins by 84,220 to 59,390.

    That's 59% for "No" and 41% for "Yes"

    Total votes cast 143,664. Turnout 81.7%


    "No" wins by 70,039 votes to 36,614.

    That's 66% for "No" and 34% for "Yes".

    Total votes cast 106,653 - a turnout of 87.4%.

    Tweet @bbcscotlandnews 04:33: Get involved

    Nearly 79,000 tweets about the Referendum between 03:00 and 04:00 - up by 2%.

    Top tweet in the last hour came from Comedian Kevin Bridges: "Haven't forced myself to stay up this late since Summerslam '97.. #indyref" retweeted over 800 times.

    The most shared photo is of a glum-looking Alex Salmond in the back of a car bound for Aberdeen Airport.

    The most shared video is of reaction in New York to the close result from Inverclyde, described as "bewildered semi-pandemonium."

    You can join the conversation by using #indyref, tweet @BBCPolitics or go to the BBC News Facebook page.

    @BBCTrending 04:32: BBC Trending

    BBC Trending tweets: #ScotlandDecides is a global topic on social media, and has been trending in France whilst Scotland (Шотландии) is trending in Russia

    04:29: Fife turnout Simon Dedman, BBC Scotland News

    Fife's official turnout is 84.1% with 254,163 votes cast.

    04:28: ANGUS RESULT

    "No" wins by 45,192 to 35,044.

    That's a share of 56% for "No" to 44% for "Yes"

    Total votes cast was 80,302. Turnout 85.7%.

    04:28: Perth & Kinross Suzanne Allan BBC Scotland

    Perth and Kinross has been such a well behaved count that the police have a few minutes to sit down.

    Police in Perth
    04:26: Falkirk vote John Curtice Professor of politics at Strathclyde University

    This is somewhere where the "Yes" side will need to be ahead in order to win the referendum.

    The fact that the "No" side have won here, albeit with no more than 53.5% of the vote, is a further straw in the wind that the "No" side have won.

    04:26: Salmond's arrival imminent

    There is a big crowd in Edinburgh awaiting First Minister Alex Salmond's arrival. He's expected at Ingliston any minute now.

    04:26: More analysis

    Prof Charlie Jeffrey of the University of Edinburgh said: "Midlothian was always going to be tough territory for the Yes side. It does not have the characteristics that we would expect to benefit "Yes".

    "What has been interesting is the declarations around Glasgow which have not followed a particular pattern.

    "We have seen Inverclyde vote against, we saw Renfrewshire vote quite strongly against but West Dunbartonshire for.

    "We expected these local authority areas to have very similar patterns. They are not being similar. It is very tough to explain exactly why one is voting one and another a different way."

    04:25: Stirling vote John Curtice Professor of politics at Strathclyde University

    This was not somewhere we expected the "Yes" side to do particularly well but the "No" success of winning by 60% to 40% is further evidence that the "No" side are going to win this referendum.

    04:24: Falkirk troubles

    "We've had our troubles in Falkirk," Scottish Labour leader Johann Lamont tells the BBC. She describes the "No" win as "a really interesting result".

    04:23: East Lothian analysis John Curtice Professor of politics at Strathclyde University

    This is not somewhere we expected the "Yes" campaign to do particularly well. It is a relatively middle class part of Scotland in which the SNP are not particularly strong. But at 38% the "Yes" share of the vote is towards the lower end of expectations.

    04:23: Better Together 'proud' Eleanor Bradford BBC Scotland Health Correspondent

    Blair McDougall tells Better Together campaigners he remains 'hopeful' based on the data crunching being done by their analysts and that they can be "proud for the rest of their lives".


    "No" wins by 58,030 votes to 50,489.

    That is 53% for "No" and 47% for "Yes".

    The total number of votes was 108,626 - a turnout of 88.7%.

    04:22: Recap

    For those who have just joined us, 11 of Scotland's 32 local authorities have now declared their results.

    Of these, nine have voted "No" and two "Yes".

    The campaign to keep Scotland in the UK is ahead in the vote share.

    04:19: Falkirk count Fiona Walker BBC Scotland

    Falkirk declaration imminent.


    "No" wins by 44,283 to 27,467.

    That is 62% "Yes" to 38% "No".

    Total votes were 71,798 - a turnout of 87.6%.


    "No" wins by 37,153 to 25,010.

    That is 60% for "No" and 40% for "Yes".

    Total votes cast was 62,225. Turnout 90.1%.

    04:14: East Dunbartonshire count

    "Yes" spirits are better here ahead of the East Dunbartonshire results.

    East Dunbartonshire

    "No" wins by 33,972 to 26,370.

    That's 56% for "No" and 44% for "Yes".

    Total votes cast was 60,395. Turnout 86.7%.

    04:11: Midlothian count

    Result at Midlothian count coming now...

    04:10: East Lothian count Kheredine Idessane BBC Scotland

    This is the scene at the Corn Exchange, with the declaration minutes away. We're expecting a big "No" vote, possibly 60 or 61 per cent against independence.

    East Lothian

    "Yes" wins by 33,720 votes to 28,776.

    That is 54% for "Yes" and 46% for "No".

    Total votes cast were 62,532, a 87.9% turnout.

    Tweet @bbcscotlandnews 04:09: Join the conversation

    Donaldo tweets: We all knew dundee was gonna be 'yes' but 57% is low compared to all the 'polls', when dundee were around 80% #indyref

    AC tweets: Love Dundee, showed true bottle. As for where I'm from Renfrewshire, disgusted but hardly surprised.

    04:08: Question 'dealt with' Ross Hawkins Political correspondent, BBC News

    tweets: Stewart Maxwell SNP: If it's a no then indy q dealt with, then priority becomes as much and as many powers as we can to Scotland

    04:07: Stirling count Reevel Alderson Home affairs correspondent, BBC Scotland

    Better Together supporters in Stirling are hugging each other in congratulation as we await an imminent declaration.

    04:06: Renfrewshire win

    Supporters celebrate a "No" victory in Renfrewshire.

    "No" celebrates
    04:05: Alex Salmond in Edinburgh David Miller BBC Scotland

    First Minister Alex Salmond's plane landed at Edinburgh Airport 20 minutes ago.

    04:05: Join the conversation

    Joanna Geary from Twitter tweets: In other news, it seems Irn Bru reached peak tweet just after polls closed #indyref http://reverb.guru/view/161577919386267480

    Tweets mentioning #indyref and Irn Bru
    04:03: Yes campaign Ken Macdonald BBC Scotland Science Correspondent

    Dundee result restarts this "Yes" party...

    Yes Scotland
    04:01: Dundee dignity

    Deacon Blue star Ricky Ross, who was campaigning for a "Yes" vote, told BBC Scotland: "That's a fantastic result from Dundee, my home city, amazing things been happening there. That will put a real smile on lots of 'Yes' people's faces."

    ricky ross
    03:59: 'Unalloyed sovereignty' Brian Taylor Political editor, Scotland

    If there is a "No" victory and if it is as a result of Gordon Brown's timetable for delivering more powers for Scotland, will Westminster accept his analysis that the unalloyed sovereignty of Westminster is at an end?

    03:58: Better Together campaign Eleanor Bradford BBC Scotland Health Correspondent

    Here is the Better Together reaction to the Dundee result.

    Better Together
    03:58: Get involved

    Nearly 75,000 tweets about the referendum sent between 02:00 and 03:00 this morning - down on the previous hour by 15%.

    Star Trek star George Takei has the most popular tweet: "Overheard: "Well, if Scotland votes for independence from the U.K., what's to keep Canada from breaking off from the U.S.?", retweeted over 1400 times.

    Comedian Kevin Bridges is among the most influential accounts. He tweeted: "A No vote being announced in Gaelic here.. #indyref" about the vote count in the Orkney Islands. It was retweeted 362 times.

    You can join the conversation via the #indyref hashtag, tweet @BBCPolitics or go to the BBC News Facebook page

    03:56: Stirling count Reevel Alderson Home affairs correspondent, BBC Scotland

    The Stirling count is expected to declare its result at about 0415. But the town's SNP MSP, Bruce Crawford is downbeat.

    Asked if he thought the result would be similar to that of neighbouring Clackmannanshire, where "No" received 54%, he said: "That would be very optimistic. I don't think we have done as well as that."

    03:55: South Lanarkshire count Catriona Renton BBC Scotland

    They've cleared away the tea, coffee and Tunnocks tea cakes...result must be coming soon!

    03:55: DUNDEE RESULT

    "Yes" wins by 53,620 to 39,880.

    That is "Yes" 57% "No" 43%

    Total ballot: 93,592. Turnout 78.8%


    "No" wins by 62,067 votes to 55,466.

    That's 53% for "No" and 47% for "Yes".

    Total votes cast were 117,612 - a turnout of 87.3%.

    03:54: Alex Salmond arrives at airport

    First Minister Alex Salmond was not at a count earlier. However, he has been seen boarding a private jet at Aberdeen Airport.

    Alex Salmond
    03:50: East Renfrewshire Jane Lewis, BBC Scotland News

    tweets: A "Yes" spokesman in East Renfrewshire tells me it would be no surprise if they won just 35% of the vote here.

    03:50: 'Cant be ignored' Andrew Black Political reporter, BBC Scotland

    Scotland Office minister David Mundell, aka Scotland's only Tory MP, has arrived at the Ingliston national count from his south Scotland constituency saying he's optimistic of a "big 'No'" in that part of the country, and replicated across Scotland.

    But he also says the significant number of people who voted "Yes" can't be ignored.

    03:50: "Yes" glumness Ken Macdonald BBC Scotland Science Correspondent

    A bit of a glum picture at the "Yes" party in Glasgow.

    "Yes" party in Glasgow
    03:47: Highland count Craig Anderson BBC Scotland

    Better Together campaigners at the Highland count in Dingwall are predicting a victory for the "No" side by 53% to 47%.

    One activist admitted: "We seem to be doing much better than we expected at the beginning of the night."

    03:47: Inverclyde analysis John Curtice Professor of politics at Strathclyde University

    This is a place where we would probably expect the "Yes" side to do rather better than average. Although it does not have a particularly large SNP vote Inverclyde does have plenty of neighbourhoods that are socially deprived.

    The fact that the vote was virtually evenly divided must thus count as further disappointment to the "Yes" campaign. The results are beginning to point towards a "No" victory although it may be a while until we are clear as to how big that victory is.

    03:47: Inverclyde result Brian Taylor Political editor, Scotland

    It was not one of the top targets for "Yes" but it was one that they would have hoped to win.

    It is a west of Scotland area where they could perhaps pitch that things could get better under independence and perhaps they had a willing audience in that regard.

    "The thing that kept it closer than Clackmannanshire could be that issue of Ferguson's shipyard where the SNP Scottish government were seen as having been instrumental in bringing about the rescue of the yard."

    03:45: Sterling bounce?

    BBC economics correspondent Robert Peston says a "No" vote would mean "sterling would bounce back" in the international money markets. He speculates this could mean a UK interest rate rise as early as November.

    03:45: Argyll & Bute count

    And still they keep coming! Ballot boxes waiting to be opened at the Argyll and Bute count at Lochgilphead.

    The declaration is expected to be around 4.30am.

    Argyll & Bute
    Tweet @bbcscotlandnews 03:44: Get involved

    Ollie Glanvill tweets: Unbelievable even Inverclyde...

    Alycia tweets: Inverclyde's votes were so close it physically pains me.

    Cath tweets: I genuinely thought Inverclyde would be a yes vote.

    03:41: Big city swing?

    James Shaw tweets: Yes Scotland chair Denis Canavan admits disappointment that No won in Clackmannanshire. Says big city could swing it back to #indyref Yes.

    03:40: Edinburgh count Laura Maxwell BBC Scotland

    Several thousand postal votes have still to be opened, scanned and verified in Edinburgh. They have just arrived at Ingliston, and were apparently late issues or replacements.

    Chris Highcock, the city's deputy counting officer, says this has delayed the declaration of turnout in the capital, but won't delay the final declaration, as other votes are being counted.

    03:39: 'Yes' groans Ken MacDonald, BBC Scotland News

    Groans and hands on heads at a "Yes" party in Glasgow as the Inverclyde result was announced.

    03:39: Perth & Kinross count Suzanne Allan BBC Scotland

    The counting staff at Perth and Kinross are still smiling - even though it's 3.29am.


    "No" wins by 27,329 to 27,243.

    That's 50.1% to 49.9%.

    The total ballot was 54,601 and the turnout 87.4%.

    03:35: Largest turnout John Curtice Professor of politics at Strathclyde University

    Latest turnout expectation has crept up slightly to 85% making it even more clearly the largest turnout in Scotland since the introduction of the mass franchise.

    03:35: Indicators of vote John Curtice Professor of politics at Strathclyde University

    Contributions from BBC reporters at the counts in both Midlothian and Aberdeen - both places where we would expect the result to be not dissimilar to that of Scotland as a whole - suggest the "No" side is quite comfortably ahead.

    If these reports are correct then the expectation of a "No" victory is likely to be fulfilled.



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