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Staying the course

Increasingly innovative planning solutions are required ?to help high-net-worth individuals mitigate tax. ?Rhona MacKinnon negotiates the obstacles

20 November 2011

With income tax rates at the highest levels since the 1980s, high-net-worth individuals (HNWI) are more interested than ever in finding ways to reduce their tax liabilities and their advisers are under pressure to offer innovative solutions.

When the highest rate of income tax increased to 50 per cent from April 2010, the use of structures such as employee benefit trusts (EBT) and employer-funded retirement benefit schemes (EFRBS) to provide tax efficient remuneration strategies grew in popularity. In some cases these structures would obtain a corporation tax deduction for the sums contributed to the EFRBS/EBT and the funds would then be passed to the individual in the form of a loan, attracting only a benefit in kind charge. This meant overall tax exposure could be as low as two per cent – a substantial saving compared with the 50 per cent rate.

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