Originally posted by Clairol
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Generally they see an "EBT" as a wholly owned company making contributions to a trust which then makes a loan to the individual director/shareholder. The company claims a CT deduction and the individual claims no tax due on the loan. HMRC says that the CT deduction is not available either at all, or until the individual is due to pay tax, in which case they might be able to issue a PAYE assessment.
A contractor loan is where money for the contractors time/expertise is paid and ends up with a promoter who may have tens/hundreds/thousands of contractors on their books. The promoter pays a contribution to a trust or similar and a loan is made to the contractor. The claim is that the loan is not taxable. That claim is not accepted as being correct by HMRC.
So there is little to chose between them aside from an EBT having some specific legislation.
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