Loans from EBTs and other Trusts

[Vallah]

Since BN66, the only feasible scheme now is through loans. So it seems unlikely that these new rules aren't targeted at EBT's. The fact is when these new rules come in, there will be no difference between an offshore and an onshore scheme, that's the whole idea. It would be very naive to think that any offshore scheme isn't now going to be targeted. The new rules are clear they reserve the right to ignore your offshore status.

EBTs have been effectively shut down. Most of the new schemes don't rely on DTAs which the HMRC announcement is cracking down on.

[BlasterBates]

EBTs have been effectively shut down. Most of the new schemes don't rely on DTAs which the HMRC announcement is cracking down on.

Interesting, so there's obviously no point in this being offshore then.

The whole point about the DTA, is that offshore schemes exploit offshore tax rates, which can only work because of the DTA.

[craig1]

I was going to have a rant on this subject and had put a good bit of text in but I've decided to delete it as pointless. Everyone has their opinions on this polarised subject and no-one is going to give way.

That said, if the scheme does get hit by HMRC for punitive taxation then it's not going to be the scheme owners that pay out when Hector comes for his pound of flesh, they'll just shrug and move onto the next, increasingly narrow and pedantic, loophole while banking their profits.

[Vallah]

Interesting, so there's obviously no point in this being offshore then.

The whole point about the DTA, is that offshore schemes exploit offshore tax rates, which can only work because of the DTA.

Your understanding of the situation is incorrect. Evn under EBT schemes, ALL income was taxed at UK rates. All of it.

[LisaContractorUmbrella]

Your understanding of the situation is incorrect. Evn under EBT schemes, ALL income was taxed at UK rates. All of it.

So the appeal of an offshore scheme is??????

[BlasterBates]

So the appeal of an offshore scheme is??????

The main appeal of the offshore scheme is that you can make a lot of money with very little risk, which is carried by your clients.

[LisaContractorUmbrella]

The main appeal of the offshore scheme is that you can make a lot of money with very little risk, which is carried by your clients.

I meant what's the appeal for a contractor?

[Vallah]

I meant what's the appeal for a contractor?

Taking home over 80% of your gross contract value.

Not being charged £30 for a same day payment from an umbrella firm.

[LisaContractorUmbrella]

Taking home over 80% of your gross contract value.

Not being charged £30 for a same day payment from an umbrella firm.

And achieving that whilst having your whole income subject to UK tax as quoted above??

[Vallah]

And achieving that whilst having your whole income subject to UK tax as quoted above??

Absolutely.