HMRC are extending their EBT settlement proposal to cover other remuneration planning but still expect full payment of the claimed PAYE and NIC. In focusing on higher risk taxpayers, HMRC are refining their approach to the largest partnerships, which are seen to present their own peculiar tax risks. The consultation on tax avoidance proposes an additional charge for using prescribed schemes that ultimately fail before the Courts. Finally, non-residents using the new Statutory Residence Test may be surprised by some of the records they will be expected to keep.
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