according to the clarification FAQ No. 6 issued by HMRC on 21 February IF the IOM employer makes the loan instead of the EBT then the Disguised Remuneration tax per B/ above does NOT apply and we are back to the benefit in kind tax on loans
In which case, why did they ever need the EBT?
You also have the problem that under Section 188(2) ITEPA the loan could be treated as written off when you leave employment, therefore you are simply deferring the liability until you leave the umbrella company (unless you plan to stay with them until death - at which point the amount payable would be taken from your estate).
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