Publications search
Comment: EBTs and EFRBS face accelerated tax charge
The draft Finance Bill clauses contain provisions which will accelerate income tax charges on EBT and EFRBS arrangements. The draft clauses are likely to be enacted in substantially their present form and will apply from 6 April 2011, with anti-forestalling provisions applying from today.
The drafting is unconventional and extremely broad in its effect. The main thrust of the changes is that any "step" that is taken in connection with EBT or EFRBS arrangements will give rise to income tax on the "value" of that step. For example, if an asset held in an EBT is earmarked for an employee (however informally), this will constitute a "step" and the "value" on which the employee is taxed will be the market value of the asset.
Taxpayers should obtain advice specific to their circumstances before they (or their trustees) take any action in relation to EBT or EFRBS arrangements.
Follow all our
latest tax updates on Twitter
09 December 2010
Author: Tax team, 9 December 2010
