HMRC have introduced a new short term settlement opportunity for the users of certain types of remuneration trust tax planning schemes where they consider that the scheme design may be fundamentally flawed.

At a glance

Overview

The settlement opportunity applies to users of schemes known as 'Remuneration Trusts' or 'Creditor Protection Trusts'.

There are three options for settlement for employment based schemes:

The settlement basis for the self-employed/partners is:

In all options:

HMRC have confirmed that where settlement is reached under these terms and all liabilities are settled, including those that are unprotected by HMRC, they will not seek to apply tax charges under Part 7A ITEPA 2003 or the loan charge.

As with the general disguised remuneration settlement opportunity time to pay will be available for individuals who do not have disposable assets and who have income less than £50,000 (5 year terms) or £30,000 (7 year terms) in the year of settlement.

Taxpayers looking to use these settlement terms should contract HMRC my emailing  This email address is being protected from spambots. You need JavaScript enabled to view it. or calling 03000 590964 in advance of the 31 July deadline as the process may take several weeks or months.

Useful guides on this topic

Disguised remuneration loan charge
What is disguised remuneration? What is the loan charge? When does the loan charge apply? Will the loan charge affect me?

Disguised remuneration 2020 settlement opportunity
What is HMRC's position on disguised remuneration loans where settlement was not reached by 30 September 2020? Can a settlement still be reached?

FAQs for Disguised Remuneration Settlements
Can I just repay my loans? Which is cheaper: the loan charge or settling? How much will it cost to settle? And many other FAQs.

External link

HMRC guidance: Settlement opportunity for users of remuneration trust tax avoidance schemes 


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