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HMRC attack on EBT loans


The recent Budget contained references to disguised remuneration. Has HMRC arranged for its plans to be contained with the 2011 tax changes? What are the details to accompany the chancellor’s references? And surely these changes will not impact EBTs which predate the 2011 rules?


The chancellor did indeed refer to disguised remuneration in his Budget speech of 16 March. The detail if you can call it that was to be found in a technical note which can be found at
The forthcoming changes will affect anyone with outstanding loans from employee benefit trusts (EBTs) and similar trusts and those who have received loans under a contractor loan scheme. In short the technical note refers to a future...
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