It seems that HMRC will finally achieve its objective of taxing all but the very oldest of loans made by EBTs by the end of 2018/19. Ashley Greenbank and Nigel Doran (Macfarlanes) explain.
During the 1990s and 2000s it was not uncommon for employer companies to pay bonuses by transferring the bonus pool to an offshore employee benefit trust (EBT). The trustees would then allocate the funds to sub-trusts for individual employees and their families; and in many cases the sub-trusts then made a loan to the employee often interest free and to be left outstanding indefinitely. In this way the employee had immediate access to his or her bonus and paid no tax on it.
HMRC tried to litigate these arrangements but with mixed results. Eventually in FA 2011 the government introduced the disguised remuneration...
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It seems that HMRC will finally achieve its objective of taxing all but the very oldest of loans made by EBTs by the end of 2018/19. Ashley Greenbank and Nigel Doran (Macfarlanes) explain.
During the 1990s and 2000s it was not uncommon for employer companies to pay bonuses by transferring the bonus pool to an offshore employee benefit trust (EBT). The trustees would then allocate the funds to sub-trusts for individual employees and their families; and in many cases the sub-trusts then made a loan to the employee often interest free and to be left outstanding indefinitely. In this way the employee had immediate access to his or her bonus and paid no tax on it.
HMRC tried to litigate these arrangements but with mixed results. Eventually in FA 2011 the government introduced the disguised remuneration...
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:
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