BIM44500 | Specific deductions: employee benefit trusts: contents
From HM Revenue & Customs · Business Income Manual
Some employee benefit trusts (EBTs) are set up to provide employees and directors with specific kinds of benefits such as shares in their employing company, pensions and other retirement benefits, accident benefits or healthcare benefits. However general-purpose EBTs have increasingly been used for tax avoidance purposes, with the aim of providing employees and directors with benefits in ways that aim to minimise or avoid liability to Income Tax and employers’ National Insurance Contributions (NICs).
In many cases the main risk may relate to Income Tax under PAYE and NICs due on amounts paid out of the EBT, rather than the availability of a Corporation Tax deduction (at some time) for the employer’s contribution. It is therefore important that staff considering deductions for employers’ contributions liaise with employer compliance staff so that all aspects of the case are considered together.
There may also be Inheritance Tax consequences if a deduction for a contribution made by a close company to an EBT is disallowed or deferred in computing the company’s taxable profits. In these cases staff considering deductions for employers’ contributions should liaise with WMBC Assets EBT Team, see BIM44550.
A full list of the contents of the guidance on deductions for employers’ contributions to EBTs is shown below. The guidance is subdivided into three main sections:
Contents27 entries
- BIM44501Specific deductions: employee benefit trusts: introduction
- BIM44505Specific deductions: employee benefit trusts: setting up costs
- BIM44510Specific deductions - employee benefit trusts: main uses
- BIM44515Specific deductions: Employee Benefit Trusts: used with employee share schemes
- BIM44520Specific deductions: employee benefit trusts: used with retirement benefit schemes
- BIM44525Specific deductions - employee benefit trusts: used with accident benefit schemes
- BIM44530Specific deductions - employee benefit trusts: used with healthcare trusts
- BIM44535Specific deductions: employee benefit trusts: general-purpose EBTs
- BIM44540Specific deductions: employee benefit trusts: general-purpose EBTs: deductions for employers’ contributions: contents
- BIM44555Specific deductions: employee benefit trusts: general-purpose EBTs: deductions for employers’ contributions: how to spot them
- BIM44560Specific deductions: employee benefit trusts: general-purpose EBTs: deductions for employers’ contributions: capital or revenue expenditure
- BIM44565Specific deductions: employee benefit trusts: general-purpose EBTs: deductions for employers’ contributions: whether wholly and exclusively
- BIM44570Specific deductions: employee benefit trusts: general-purpose EBTs: deductions for employers’ contributions: timing of deductions
- BIM44571General-purpose EBTs: deductions for employers' contributions: permanent disallowance of contribution
- BIM44573Specific deductions: employee benefit trusts: general-purpose EBTs: timing of deductions for contributions: contents
- BIM44575Specific deductions: employee benefit trusts: general-purpose EBTs: timing of deductions for contributions: introduction
- BIM44580Specific deductions: employee benefit trusts: general-purpose EBTs: timing of deductions for contributions: overview
- BIM44585Specific deductions: employee benefit trusts: general-purpose EBTs: timing of deductions for contributions: what it applies to
- BIM44595Specific deductions: employee benefit trusts: general-purpose EBTs: timing of deductions for contributions: qualifying benefits
- BIM44600Specific deductions: employee benefit trusts: general-purpose EBTs: timing of deductions for contributions: qualifying expenses
- BIM44605Specific deductions: employee benefit trusts: general-purpose EBTs: timing of deductions for contributions: computing adjustments
- BIM44610Specific deductions: employee benefit trusts: general-purpose EBTs: timing of deductions for contributions: computing adjustments: example
- BIM44611Specific deductions: employee benefit trusts: general-purpose EBTs: deductions for contributions: computing adjustments: example
- BIM44615Specific deductions: employee benefit trusts: general-purpose EBTs: timing of deductions for contributions: payments ‘out of’ contributions
- BIM44620Specific deductions: employee benefit trusts: general-purpose EBTs: timing of deductions for contributions: transfers of assets to employees
- BIM44630Specific deductions: employee benefit trusts: general-purpose EBTs: timing of deductions for contributions: interaction of Corporation Tax rules with employee share schemes deductions
- BIM44635Specific deductions: employee benefit trusts: general-purpose EBTs: timing of deductions for contributions: interaction with unpaid remuneration rules