Settlement considerations following the Rangers decision

Following the Supreme Court’s recent judgment in the Rangers case, many employers who had established employee benefit trusts (EBTs) are facing enforcement notices in respect of income tax and National Insurance contributions (NICs).

In addition, HMRC is inviting participants of what it considers to be disguised remuneration schemes (including EBTs, employer-funded retirement benefit schemes (EFRBS), contractor loan schemes and self-employed benefit schemes), to register an interest in settling their tax liabilities arising from the use of such arrangements.