Former Rangers chairman Sir David Murray will be expected to continue the Big Tax Case fight all the way to the Supreme Court.

The taxman won round three of the long running fight over whether Rangers were liable for a £46.2 million bill on the use of Employee Benefit Trusts (EBTs) to pay players and staff.

But it will be a surprise to many if the proud 64-year-old entrepreneur does not take the case all the way to the final round,  and the final appeal arbiter, the Supreme Court.

While the taxman was preparing to launch further cases against companies to claw back millions over the use of employee benefit trust (EBT) loans to players and other staff pay staff, it will be expected that they will still have to plough resources into another appeal. And this time they will not be the appellants.

For Mr Murray, who will have been knocked down and bloodied by the latest judgement,  the issue is a matter of principle, and he will be expected to come off the canvas and keep fighting.  Cost will not be a factor.

HMRC has said that EBTs were used by more than 5000 UK firms, including football clubs in England. The Rangers case was seen as a test case, which would add weight to its bid to claw back many millions of pounds from their use.

Under Mr Murray, Rangers used the scheme from 2001 until 2010 to give millions of pounds of tax-free loans to players and other staff.

It was a system that was drawn up in consultation with his accountants that his advisers felt was within the law and allowable.

HMRC began to target Mr Murray and the club in the spring of 2010, nine years after the club starting using the scheme, and as EBT loopholes were being closed.

New regulations a year after the Rangers probe was launched effectively blocked the use of EBTs but tax inspectors were looking into contracts and structures set up prior to that.

An EBT is a legal structure which can be used to deliver various benefits to employees. They were previously used to enable companies to minimise the income tax and national insurance charges on pay to high-earning employees and directors, as well as allow those companies to claim corporation tax deductions on payments into the trust.

However, many of the previous tax advantages of that particular arrangement were removed as part of the 2011 Finance Act.

The Rangers payments were said to be publicly documented. The club's annual report for 2008 highlights the Murray Group Management Ltd Remuneration Trust while the Rangers Employee Benefit Trust has also been used. In the financial year of 2008, for example, £2.29m was contributed to employee trusts with £4.98m paid by the club a year earlier.

The former Ranger chief is keeping his counsel for the time being and will be expected to make a statement over his position over the coming days.

The overriding criteria for pursuing the matter to the ultimate appeal court is whether he can win.

And his legal counsel have long since been convinced that he can.

Before the latest appeal, Mr Murray's Murray International Holdings (MIH), which formerly owned Rangers, had twice successfully argued that EBT were loans and therefore exempt from tax.

In 2012 a First Tier Tax Tribunal decided that the club did not act illegally in its use of Employee Benefit Trusts.

It found most of the trusts were "valid" and loans "recoverable" by the trust, although it conceded some advances to players were taxable and any bill is likely to be "substantially reduced" from the initial £46.2m assessment.

The tribunal said that as the payments had been made as loans rather than earnings, as set out in the terms of each EBT, they could therefore be recovered from the member of staff or that person's estate.

In the rematch, when HMRC appealed the 2012 ruling in relation to payments to sub-trusts in 2014 Lord Docherty dismissed the legal bid.

But the new judgement made by Lord Carloway, sitting with Lord Menzies and Lord Drummond Young changed all that.