ICAEW.com works better with JavaScript enabled.

Disguised remuneration

The new disguised remuneration tax charge comes into force next April. Jenny Hulme looks at what this means for finance departments.

It would be easy for those not familiar with employee benefit trust (EBT) loans to read the headlines and think the tax office has unfairly taken us all by surprise with a retrospective tax charge for these disguised remuneration schemes. Most notable of those headlines is last year’s much publicised Supreme Court judgement in Glasgow Rangers Football Club’s tax case.

Nevertheless, whichever way you look at them, and however ‘properly’ administered, EBT loans from a trust in the UK or offshore to hold cash and/or assets for the benefit of employees have been in existence for a long time. Even if they’re out of the spotlight, they have always been seen as a tax avoidance tool. They have worked, historically at least, via companies setting up a trust (as a separate entity) and transferring property into it.

This is an extract from the Business & Management Magazine, Issue 267, September 2018.

Find out more


Full article is available to Business and Management Faculty members and subscribers of Faculties Online.


To read the complete article, join the Business and Management Faculty or subscribe to Faculties Online.