Loans from EBTs and other Trusts

[geoff from contracta IOM]

I'd be genuinely interested to understand why you believe that. Can you post a few notes please on why your scheme won't get caught by that fairly simple test: UK resident + UK earned income + using off-shore scheme to avoid UK taxation = Caught.

Because there is no " earned income " by the individual

[Vallah]

I'd be genuinely interested to understand why you believe that. Can you post a few notes please on why your scheme won't get caught by that fairly simple test: UK resident + UK earned income + using off-shore scheme to avoid UK taxation = Caught.

I'd imagine it's for the simple reason that his scheme doesn't make use of a DTA, which is what the proposed legislation appears to be keen to clamp down on.

[LisaContractorUmbrella]

Because there is no " earned income " by the individual

Do you run the Isle of Man lottery Geoff

[craig1]

I'd imagine it's for the simple reason that his scheme doesn't make use of a DTA, which is what the proposed legislation appears to be keen to clamp down on.

I assume his scheme is this or similar, if so then it relies on HMRC Tax Manual: Isle of Man Double Taxation agreement sections to stop UK taxpayers being double hit and let them take home such a high % of income.

[craig1]

Because there is no " earned income " by the individual

Seriously? Where does the money come from then? Contractor turns up for work then bills client/agency, surely that's income by anyone's reasonable interpretation. It's inconceivable that a court would take any other interpretation. I had a look at the Contracta website and, if that's the scheme you're touting, then you're touting self-employed consultants and it openly discussed "income"

[geoff from contracta IOM]

Do you run the Isle of Man lottery Geoff

I appreciate you have an agenda Lisa but surely you have at least taken the time to study the detail of the alternatives to umbrella companies, I have taken the time to study all the alternatives to my scheme so that I can offer genuine advice on the best option and yes for some individuals that may be umbrella or a Ltd Co.

[LisaContractorUmbrella]

Doesn't that rely on services being performed in IOM?

"For the purposes of the credit paragraph (Elimination of double taxation), profits or remuneration for personal (including professional) services performed in the Isle of Man are deemed to be income from sources within the Isle of Man"

[geoff from contracta IOM]

Seriously? Where does the money come from then? Contractor turns up for work then bills client/agency, surely that's income by anyone's reasonable interpretation. It's inconceivable that a court would take any other interpretation. I had a look at the Contracta website and, if that's the scheme you're touting, then you're touting self-employed consultants and it openly discussed "income"

You work through an agency presumably ? is their margin your income as well ? And the individual does receive an income just not the full contract value.

[LisaContractorUmbrella]

I appreciate you have an agenda Lisa but surely you have at least taken the time to study the detail of the alternatives to umbrella companies, I have taken the time to study all the alternatives to my scheme so that I can offer genuine advice on the best option and yes for some individuals that may be umbrella or a Ltd Co.

I would be more than happy to consider the scheme that you are offering Geoff and any other like it but you and your fellow providers refuse to provide details so we are unable to make an informed judgement. I realise my remark was flippant and I apologise but your statement did seem a little ridiculous under the circumstances

[geoff from contracta IOM]

Doesn't that rely on services being performed in IOM?

"For the purposes of the credit paragraph (Elimination of double taxation), profits or remuneration for personal (including professional) services performed in the Isle of Man are deemed to be income from sources within the Isle of Man"

In brief No, I can only speak for my scheme though