SPEED READ HMRC are devoting increased resources to enquiries involving EBTs as the department has a significant backlog of such cases. While the disguised remuneration legislation will deter many in future, there are still significant historical issues to resolve, and HMRC have issued their view of many of the IHT down-sides of such planning, hoping this will persuade users to reach settlements. This more focused approach to dispute resolution is spreading across HMRC, with a greater desire to engage in discussions to unlock potential solutions where possible. At the same time HMRC and advisers are getting accustomed to a new and potentially more punitive penalty regime that requires greater factual input than previously.