Alternatives to EBTs for non-doms & HNWIs

Jo Summers

Jo Summers reviews alternatives for HNWI and non-dom clients to structure remuneration packages, in light of the new disguised remuneration rules

The disguised remuneration charge announced on 9 December 2010 seemed to be the end for Employee Benefit Trusts (EBTs) and many other remuneration structures.

New Part 7A of ITEPA 2003 is designed to ensure any employment income provided through third parties is immediately subject to income tax and NICs.

So what are the alternatives for non-domiciled and high-net worth individuals (HNWIs) to reduce the UK tax burden on their earnings?

Are employee benefit trusts dead?

Perhaps ironically EBTs could still play a part in remuneration planning for non-doms and HNWIs.

An EBT is after all a discretionary trust in favour...

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Jo Summers reviews alternatives for HNWI and non-dom clients to structure remuneration packages, in light of the new disguised remuneration rules

The disguised remuneration charge announced on 9 December 2010 seemed to be the end for Employee Benefit Trusts (EBTs) and many other remuneration structures.

New Part 7A of ITEPA 2003 is designed to ensure any employment income provided through third parties is immediately subject to income tax and NICs.

So what are the alternatives for non-domiciled and high-net worth individuals (HNWIs) to reduce the UK tax burden on their earnings?