In this short note, we study pairwise edge-disjoint rainbow spanning trees in properly edge-coloured complete graphs, where a graph is rainbow if its edges have distinct colours. Brualdi and Hollingsworth conjectured that every $K_n$ properly edge-coloured by $n-1$ colours has $n/2$ edge-disjoint rainbow spanning trees. Kaneko, Kano and Suzuki later suggested this should hold for every properly edge-coloured $K_n$. Improving the previous best known bound, we show that every properly edge-coloured $K_n$ contains $Ω(n)$ pairwise edge-disjoint rainbow spanning trees. Independently, Pokrovskiy and Sudakov recently proved that every properly edge-coloured $K_n$ contains $Ω(n)$ isomorphic pairwise edge-disjoint rainbow spanning trees.