disguised remuneration

Budget 2020 – The Usual Suspects

You would have thought that after, what, 10 years of specific anti-avoidance legislation HMRC would have cracked the tax avoidance nut. But no, the latest proposals in Budget 2020 would suggest that HMRC think otherwise. As the Budget ‘Red Book’...

How hard is it to pay tax?

You would think it should be very easy to pay money to HMRC. After all, as we are being regularly reminded, it is the very raison d’etre for its existence. It is the channel for funds to the Treasury and...

‘Twas the afternoon before Christmas

If such a thing even exists, the Friday afternoon before the Christmas Break is rarely an exciting or memorable occasion in the tax world. Not like 31 January, say, or the morning before the Budget announcement, when minds are sharp...

THE LOAN CHARGE IS STILL COMING TO A PLACE NEAR YOU!

There has been a lot of media coverage concerning the communications between HMRC’s Second Permanent Secretary; Jim Harra and the Treasury Select Committee which was published on 1 March 2019. The communication relates on the Disguised Remuneration Settlement opportunity and...

The 2019 DR Loan Charge – Act now!

For participants in what HMRC calls Disguised Remuneration tax avoidance, we previously reported in August 2018 the details of what is the final settlement opportunity. The “carrot” was stated to be resolution and finality of long standing investigations with the...

Disguised remuneration – an update

We reported earlier this year on how to take advantage of the final opportunity in settling any liabilities arising from various forms of historic tax planning which HM Revenue and Customs (HMRC) badges under the disguised remuneration banner. We also...

HMRC ramps up pressure on EBTs

The expectation that HMRC would use the Supreme Court’s decision in the Rangers Case as the basis of issuing Follower Notices and Accelerated Payment Notices has now become a reality.  As set out in our previous blog HMRC is required...

2019 Loan Charge – another weapon for HMRC

If you have used remuneration tax planning involving loans (after 6 April 1999) and choose not to settle with HMRC using the current disguised remuneration settlement opportunity, then any outstanding loans as at 5 April 2019 will be subject to...

Settling disguised remuneration arrangements

In August last year we reported on the announcement of HMRC’s final settlement opportunity for Employee Benefit Trust (EBT) users as a result of the infamous Rangers decision in the Supreme Court. This settlement opportunity is also for Employer Financed...

Rangers and Follower Notices – Key Dates

Following the Supreme Court’s decision in the Rangers Football Club Employee Benefit Trust (“EBT”) case last year. HMRC is sending Follower Notices to companies with EBTs, users of Employer Financed Retirement Benefit Schemes (EFRBS) and other (what HMRC terms) similar...

Disguised Remuneration – A further clampdown ahead

Following the introduction, in 2011, of anti-avoidance legislation to curb tax avoidance in the form of Disguised Remuneration, HM Revenue and Customs (HMRC) have increasingly sought to legislate and litigate against remuneration arrangements which seek to minimise tax liabilities. The...