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EBTs
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EBTs
EBTS
JTC Employer Solutions Trustee Ltd and others v W Garnett and others
High Court permits rescission of sub-trust appointments saving IHT for EBTs caught by income tax avoidance rules.
Other cases that caught our eye: 15 September 2023
EBTs and penalties for inaccuracies in returns: Delphi Derivatives Ltd v HMRC [2023] UKFTT 722 (TC) (18 August) is the second decision on the Clavis Herald avoidance scheme in recent weeks. The scheme involved an EBT but its structure was...
HMRC’s trust registration service: changes for employee trusts
Graeme Whitfield
Liz Hunter
Liz Hunter and Graeme Whitfield (KPMG) examine the new registration requirements for EBTs and EOTs.
Tax and the City review for June 2020
Mike Lane
Zoe Andrews
Deeming rules, debits, partnerships and pension funds all feature within this month's update, by experts at Slaughter and May.
Directors’ duties and EBT schemes
Matthew Findley
Dominic Stuttaford
The after-effects of the
Rangers
decision are being felt beyond the tax tribunals. Dominic Stuttaford and Matthew Findley (Norton Rose Fulbright) review lessons from two recent cases on directors' duties for unpaid PAYE and NICs relating to unsuccessful EBT schemes.
Inheritance tax and the requirement to correct
Jon Preshaw
Natalie Martin
Jon Preshaw and Natalie Martin (PwC) identify areas of possible risk.
The corporate tax world in 2017
Ashley Greenbank
Ashley Greenbank (Macfarlanes) picks out some highlights in a year of political and economic turmoil.
The practical issues outstanding following Rangers
Karen Cooper
Karen Cooper (Cooper Cavendish) examines the impact of the recent Supreme Court decision on employee benefit trusts, and speculates on HMRC’s approach to similar structures.
Private client briefing for July 2017
Andrew Goldstone
Stuart Adams
Andrew Goldstone and Stuart Adams (Mishcon de Reya) provide the monthly update on the taxation of private clients.
Disguised remuneration: the new EBT loan charge
Nigel Doran
Ashley Greenbank
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.
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EDITOR'S PICK
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
1 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
2 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
3 /7
Estoppel and abuse of process in VAT
Claire Logan
4 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
5 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
6 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
7 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
Estoppel and abuse of process in VAT
Claire Logan
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
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UK closes the door on foreign branch loss relief
VAT capital goods scheme changes
New guidance on UK-India social security agreement
Mandatory registration brought into force, eventually
HMRC annual report: compliance yield tops £50bn
CASES
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St Patrick’s International College Ltd and others v HMRC
M Lambourne and another v HMRC
HMRC v Align Technology Switzerland GmbH and another
Other cases that caught our eye: 17 July 2026
HMRC v BlueCrest Capital Management (UK) LLP
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Directors’ liability: tax schemes
BlueCrest: the impact for asset managers
When Ramsay does not rescue HMRC
Tax Update 2026: Plans to reform the income tax payment regime: a significant acceleration of ITSA tax liabilities
Tax Update 2026: Modernising the distributions framework: familiar routes for extracting value or reorganising companies may change
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When Ramsay does not rescue HMRC
Tax and the City for July 2026
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HMRC v BlueCrest Capital Management (UK) LLP