Dawn Register comments on the Employee Benefit Trusts settlement opportunity deadline

Date: 04 Mar 2015


Commenting on the Employee Benefit Trusts (EBT) settlement opportunity deadline of Tuesday 31 March 2015, Dawn Register, partner, Tax Dispute Resolution, BDO, said:

“In advance of the Employee Benefit Trusts (EBT) settlement opportunity 31 March deadline, HMRC has been ratcheting up its messaging, sending out ‘shove’ rather than ‘nudge’ letters; marking a stern reminder that the deadline will not be extended.

“HMRC is currently working on more than 6,000 cases; 1,000 have settled so far with ¬£900m collected, highlighting that the campaign has already been a successful one. Pending the National Insurance Contributions (NIC) regulations no Accelerated Payment Notices (APNs) have yet been issued for EBT cases. However, the NIC regulations are now in force so APN’s will start to be issued next month, resulting in a bill for the full amount of tax that HMRC considers is due. This will come as huge shock for many users of EBT-type arrangements.

“Our message is that corporates or individuals that have been involved in an EBT arrangements should consider the risks and benefits of using the settlement opportunity prior to the end of March; not doing so means that taxes and interest payments could be more severe in the future. More seriously they could face a costly litigation battle as a bullish HMRC gears up to start legal proceedings in all cases and will not allow appeals to sit behind one lead case.‚Äù

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