HMRC continue to encourage businesses that have
used EBT settlements Employee Benefit Trusts (EBTs) and similar arrangements, to ‘settle’ their affairs and conclude any outstanding enquiries.

The Bedrock team are supporting a number of businesses that have made the sometimes difficult decision to ‘settle’ in advance of litigation and the proposed introduction of new legislation. We can take full control of the settlement process which includes:

  • Collation and review of all relevant strategy information
  • Review of the enquiry and assessment status of the company and relevant beneficiaries
  • Managing any further correspondence in respect of APNs or enquiries relating to the planning
  • Producing a full settlement calculation
  • Drafting of a formal settlement approach to HMRC
  • Reviewing HMRC’s calculations to ensure they are in line with current terms and our own workings
  • Reviewing the settlement agreement

We usually recommend closing any trusts associated with the planning to avoid any future tax charges and trustee fees. In these instances we can:

  • Manage all liaison with the trustees
  • Ensure the trust structures are closed within 90 days to avoid any further IHT liabilities
  • Draft a letter of recommendation for you to formally request that the trusts are closed post settlement
  • Provide a briefing note detailing our recommended steps to take post settlement. The note will include suggested tax return narratives and further advice surrounding the closure/cancellation of any assessments and enquiries

If you’d like to know more about how the Bedrock team can help settle any tax planning arrangements get in touch today to have a free and confidential exploratory conversation.

Case Study: company EBT settlement

Where a company wants to settle several Employee Benefit Trusts (EBTs) with HMRC.

Read case study

Case Study: EBT Settlement

HMRC is issuing Accelerated Payment Notices to companies and individuals who have undertaken tax planning such as those that feature Employee Benefit Trusts. Though the planning arrangement may still be subject to future litigation and has a good chance of being successfully defended through the courts, some businesses may decide they wish to settle with HMRC.

Read case study
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