Subsequent to the decision of the Supreme Court in RFC 2012 plc (in liquidation) (formerly Rangers Football Club plc) v Advocate General for Scotland, HMRC are advising tax agents and accountants that they will be inviting users of disguised remuneration schemes to settle their tax liabilities in order to prevent further immediate action by HMRC. The Supreme Court decision that was in favour of HMRC, made it clear that where a payment is established as being employment related earnings, it is not possible to avoid tax by diverting or paying the funds to a third party and is relevant to a wider bracket of earnings-related tax avoidance schemes including Employee Benefit Trusts, Employer-Funded Retirement Benefit Schemes, Contractor Loans Schemes, and Self-Employed Benefit Schemes – commonly known as disguised remuneration schemes.
HMRC will be inviting participants of such disguised remuneration schemes to settle their liabilities. Our firm is assisting a number of such clients. If you have used any scheme and would like to clear your record, please contact us on 0207 998 1834 for a free and confidential consultation.