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Settlement opportunity for remuneration trust arrangements

03 May 2022 / Richard Philson , Dominic Hall
Issue: 4838 / Categories: Comment & Analysis
Worth settling?

Key points

  • HMRC’s new settlement opportunity is the latest chapter in its challenge against ‘disguised remuneration’ arrangements.
  • It is an opportunity to agree the tax treatment with HMRC and achieve closure without litigation.
  • Careful analysis of the facts is required to determine whether settlement is appropriate and which calculation basis should apply for each taxpayer.
  • There is a strict application deadline of 31 July 2022 which includes submitting calculations to HMRC.

On 11 April 2022 HMRC released a new settlement opportunity (RTSO) for participants in tax avoidance arrangements commonly known as remuneration trusts (RTs) or creditor protection trusts (

We understand these arrangements were chiefly promoted by one prominent adviser and have been implemented by a significant number of companies owner-managed businesses and self-employed sole traders or partnerships. They typically involve a contribution of funds to a trust followed by loans to directors/shareholders or business owners...

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