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HMRC & EBTs

Ronnie Macdonald, Avoidance Investigation, Anti Avoidance Group, HMRC, explains what action HMRC is taking to seek to tax employee benefit trusts appropriately

 
Ronnie Macdonald Avoidance Investigation Anti Avoidance Group HMRC explains what action HMRC is taking to seek to tax employee benefit trusts appropriately
 
Since the late 1990's HMRC has been investigating cases with employee benefit trusts (EBTs) where the employer has sought an immediate deduction for corporation tax in respect of its contributions to the EBT whilst the EBT is used to channel funds to employees without accounting for PAYE tax or NI contributions.
 
HMRC's first challenge before the Courts arose in the case of Dextra Accessories Ltd v Macdonald. At dispute was the deductibility of payments to the EBT for the purposes of Sch. D...

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