*We have now seen a number of settlement proposals from HMRC in relation to Employee Benefit Trusts, “EBTs”, where the deduction for Corporation Tax has been disallowed.*
*This is in line with the decision made in the case of Wired Orthodontics Ltd & Ors v HMRC \[2023] UKFTT 17 (TC), which concerned a PAYE assessment on funds routed through an EBT.*
