HMRC has recently published FAQs on the employee benefit trust settlement opportunity (EBTSO). Jim Wilson and Paul Cook consider whether the EBTSO is an opportunity not to be missed.
Background
For nearly two decades HMRC has been enquiring into and challenging arrangements involving employee benefit trusts (EBTs).
Despite a long line of litigation over the years the judgments in these cases failed to provide sufficient clarification of the PAYE and NIC position relating to EBT arrangements.
With HMRC becoming increasingly concerned at the scale and continued use of EBTs during 2011 two separate measures were introduced: the first largely to resolve the future position and the second which sought to resolve the historic position.
Going forward the ‘disguised remuneration’ provisions (which had first been published in draft in December 2010 as part of Finance Bill 2011) were finally enacted – after much
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
HMRC has recently published FAQs on the employee benefit trust settlement opportunity (EBTSO). Jim Wilson and Paul Cook consider whether the EBTSO is an opportunity not to be missed.
Background
For nearly two decades HMRC has been enquiring into and challenging arrangements involving employee benefit trusts (EBTs).
Despite a long line of litigation over the years the judgments in these cases failed to provide sufficient clarification of the PAYE and NIC position relating to EBT arrangements.
With HMRC becoming increasingly concerned at the scale and continued use of EBTs during 2011 two separate measures were introduced: the first largely to resolve the future position and the second which sought to resolve the historic position.
Going forward the ‘disguised remuneration’ provisions (which had first been published in draft in December 2010 as part of Finance Bill 2011) were finally enacted – after much
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
