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HMRC sets out new process to settle ‘disguised remuneration’

10 November 2017

A new opportunity to settle outstanding tax enquiries in relation to ‘disguised remuneration’ was released by HMRC this week. The new settlement opportunity will be available until April 2019.

This follows the Supreme Court’s decisions in July in favour of HMRC in the long-running battle relating to Rangers Football Club’s use of employee benefit trusts (EBTs) in connection with players’ remuneration between 2001 and 2010. The Rangers decision was expected to have significant ramifications for other companies who used EBTs before the introduction of the ‘disguised remuneration’ legislation in 2011. You can read our earlier article on the topic here.

“The new settlement opportunity is a further reflection of HMRC’s efforts to bring these enquiries to a conclusion by the time the new loan charges relating to disguised remuneration come into effect in April 2019,” said David Scott, tax partner.

Anyone wanting to take part in the settlement opportunity needs to register their interest with HMRC by 31 May 2018.

Further details of the settlement opportunity can be found here.

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