HMRC has opened approximately 12,000 investigations into the use of employee benefit trusts (EBTs) in the past five years, according to Pinsent Masons. With the disguised remuneration loan charge deadline approaching, the pressure is also on taxpayers to settle any outstanding EBT cases.
Josie Hills, a senior tax manager at Pinsent Masons, said: ‘The thousands of cases show just how wide a net HMRC is casting when investigating employee benefit trusts. HMRC has kept strong pressure on EBTs for several years now, even after the new loan charge was first announced in 2016, to recoup what it sees as lost tax’.
EBTs were used widely by hedge funds and banks to manage tax payments on bonuses, before many of the tax advantages were removed by the new disguised remuneration rules. The high-profile Rangers Football Club (RFC 2012) case [2017] UKSC 45, found players and executives at the club were liable for tax in respect of an EBT avoidance scheme.
HMRC has opened approximately 12,000 investigations into the use of employee benefit trusts (EBTs) in the past five years, according to Pinsent Masons. With the disguised remuneration loan charge deadline approaching, the pressure is also on taxpayers to settle any outstanding EBT cases.
Josie Hills, a senior tax manager at Pinsent Masons, said: ‘The thousands of cases show just how wide a net HMRC is casting when investigating employee benefit trusts. HMRC has kept strong pressure on EBTs for several years now, even after the new loan charge was first announced in 2016, to recoup what it sees as lost tax’.
EBTs were used widely by hedge funds and banks to manage tax payments on bonuses, before many of the tax advantages were removed by the new disguised remuneration rules. The high-profile Rangers Football Club (RFC 2012) case [2017] UKSC 45, found players and executives at the club were liable for tax in respect of an EBT avoidance scheme.