Disguised remuneration and EBTs

FORTHCOMING CHANGE: As announced at Autumn Budget 2024, the government has commissioned an independent review of the loan charge. The review, announced on 23 January 2025, will ‘examine the barriers preventing those who are subject to the loan charge but have not already settled and paid their tax liabilities in full from reaching resolution with HMRC’ and will ‘recommend ways in which they can be encouraged to settle with HMRC’. To assist with the review, a call for evidence, aimed at those who remain subject to the loan charge (and their advisers), was published on 28 March 2025. The outcome of the review, with recommendations, will be reported and presented to the Exchequer Secretary to the Treasury ‘by Summer 2025’. For more on the review, see News Analysis: Autumn Budget 2024—Independent review of the loan charge. HMRC has confirmed the operational activity it will undertake while the independent review is ongoing. This includes sending letters (and a Q&A document) to affected taxpayers setting out whether HMRC believes the disguised remuneration arrangements used by the taxpayer will be of the type considered by