Tax planning for EBTs and EFRBS

Over the last year HMRC has issued 'Spotlight' 5 and 6 in relation to Employee Benefit Trusts (EBTs) and Employer-financed retirement benefits schemes (EFRBS) (see http://www.hmrc.gov.uk/avoidance/spotlights.htm) highlighting their uses in circumstances in which it considers to be tax avoidance (namely the allocation of funds within an EBT for the benefit of employees without the deduction of PAYE and the contribution to an EFRBS or the transfer of amounts from one EFRB to another solely in order to claim corporation tax relief). The Government has further announced in the recent Budget that it would take action to prevent attempts to avoid income tax and NIC through the use of EBTs and other arrangements 'to disguise payments of remuneration' and intends to introduce anti-avoidance legislation with effect from...