This confirms their view that the case has a wide application, covering in addition to Employee Benefit Trusts (EBTs) disguised remuneration paid through employer funded retirement benefit schemes (or EFRBs’s) or contractor loan schemes (a variation on EBTs).
This development is to be expected. It emphasises the importance for employers to review tax planning involving payments to third parties and consider whether the Rangers decision creates risks and exposures which may not have been identified and if so, how best to address them.
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