HMRC to invite users of disguised remuneration schemes to settle tax liabilities

Released 10 August 2017

Following the decision of the Supreme Court in RFC 2012 Plc (in liquidation) (formerly The Rangers Football Club Plc) (Appellant) v Advocate General for Scotland, HMRC are notifying agents that they will be inviting participants of disguised remuneration schemes to settle their tax liabilities in order to prevent further immediate action by HMRC.

The Supreme Court decision made it clear that where a sum is established as being employment earnings, it is not possible to avoid tax by diverting or paying them to someone else and is relevant to a wide range of earnings-related tax avoidance schemes including Employee Benefit Trusts, Employer-Funded Retirement Benefit Schemes, Contractor Loans schemes, and self-employed benefit schemes – known collectively as disguised remuneration schemes.

HMRC will be inviting participants of such schemes to register an interest in settling their tax liabilities arising from the use of these arrangements in order to prevent further immediate action by HMRC, stop interest charges from rising further and provide access to extended payment terms where needed.

Agents who wish to contact HMRC about settling clients’ affairs should email ca.admin@hmrc.gsi.gov.uk; or if they are already speaking to someone in HMRC about the use of a disguised remuneration scheme, or have a customer relationship manager, contact them.

For more information getting out of a tax avoidance scheme, see Pay the tax you owe - getting out of a tax avoidance scheme.

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