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EBT settlements in practice

James Hume and Steve Edge examine the issues to consider before engaging in substantive discussions with HMRC on the settlement opportunity for employee benefit trusts.

For many employers 2013 should be the year that they begin to make progress in dealing with the potential tax liabilities in respect of their employee benefit trust (EBT) arrangements.

That will mark a change from 2012 which was in most cases a ‘wait and see’ year in this regard. When not waiting for the publication of HMRC’s FAQs on the EBT settlement opportunity (EBTSO) employers and their advisers were trying to find out on what the terms other settlements were being reached and speculating as to what the First-tier Tribunal’s decision in the Rangers case (Murray Group Holdings Ltd v HMRC [2012] UKFTT 692 (TC)) might be.

We have now had HMRC’s FAQs for nearly...

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