Disguised Remuneration Arrangements

Tuesday, December 15, 2015

A PwC Tax investigations newsflash: Autumn Statement - One of the key announcements in the Autumn Statement was that the Government intends to "take action on disguised remuneration schemes":


3.87 Disguised remuneration - The government intends to take action against those who have used or continue to use disguised remuneration schemes and who have not yet paid their fair share of tax. The Government will also consider legislating in a future Finance Bill to close down any further new schemes intended to avoid tax on earned income, where necessary, with effect from 25 November 2015.

At this stage we do not have specific details about what form this action will take. However, it is clear that, having given users of arrangements such as employee benefit trusts (EBTs) and employer financed retirement benefit schemes (EFRBS) the chance to reach agreement with HMRC over a number of years, the Government intends to introduce measures to target the remaining users of such arrangements. It is, therefore, essential that anyone who has not reached a settlement agreement in respect of their planning seeks professional advice about their options.

Our experience is that HMRC are still willing to discuss settlement terms. The Autumn Statement announcement should encourage people who were unsure whether to settle their liabilities to come forward now, before HMRC take further action to either make the terms of settlement worse, or to litigate.

PwC's Tax Dispute Team have helped hundreds of clients gain certainty over the tax liabilities arising from historic planning arrangements and have particular expertise in resolving HMRC enquiries into complex offshore trust structures.

To arrange a free initial discussion please contact:
Scotland - Jon Preshaw - 07921108774
North West - Ben Roseff - 07715211869
North East - Richard Alderson - 07739874043
Midlands - Gill Thomson - 07740918393
South West - Ian Sanderson - 07764902737
South East - Jeremy Johnson - 07889643465
London - Matthew Taylor - 07841632394
London - Jess McLellan - 07808728483

Visit us online: http://www.pwc.co.uk/services/tax/insights/tax-disclosures.html

Jonathan Preshaw
PwC | Director 
PricewaterhouseCoopers LLP

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