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Cunning disguise

06 September 2011 / Nigel Holmes , Graham Poles
Issue: 4320 / Categories: Comment & Analysis , Employees , Income Tax
HMRC do not like employee benefit trusts. NIGEL HOLMES and GRAHAM POLES examine the state of play, problems, and planning opportunities


  • HMRC’s barrage of anti-employee benefit trust measures.
  • Corporation tax relief depends on payment being made under FA 2003 Sch 24.
  • Possible solutions to an inheritance tax charge.
  • Despite the Sempra and Dextra cases HMRC offer a settlement opportunity.
  • Disguised remuneration ITEPA 2003 Part 7A and loans to employees.

We have been advising on employee benefit trusts (EBTs) since the late 1990s. In that time we have seen three Labour governments one coalition government the turn of the 21st century and concerns over the millennium bug.

We have had the 9/11 and 7/7...

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