Some advice from the 'Old hands' please.....

[The Wikir Man]

DTA was one scheme, EBT is a different scheme. The fact that they are both run from IOm is irrelevant.

Ah, OK.

No, the EBT isn't caught by BN66, but could well become a target of HMRC given the latest budget notes:

In a related move, and in line with BN66, the government says it will stop companies from claiming "excessive" tax relief for foreign taxes by "abuse" of the UK's double taxation treaties.

To do this, the government will deploy a package of new measures from April 1, 2010

Linky.

[sal626]

Actually the quote you are looking for is:

"To this end, legislation will be made from April 6, 2011, to stop businesses using Employee Benefit Trusts to make 'disguised payments' of remuneration to trustees. "

Same linky...

[Vallah]

Actually the quote you are looking for is:

"To this end, legislation will be made from April 6, 2011, to stop businesses using Employee Benefit Trusts to make 'disguised payments' of remuneration to trustees. "

Same linky...

Exactly. EBTs are nothing to do with BN66. HMRC might ensure that they cease to be effective from next April, but they'd be extremely hard to attack retrospectively. The law as it stands is pretty rigorous.