Employee Beneficiary Trusts (EBTs) and Employer Funded Retirement Benefit Schemes (EFRBs) – OneE

Main provider OneE Tax Limited’s recent announcement that there is now no reasonable prospect of successfully defending EFRBS and EBT planning following the high-profile victory for HMRC in the Rangers case has left many participants in these schemes facing unexpected and substantial personal liabilities.

FS Legal is one of the very few law firms in the country to specialise in claims arising from Employee Beneficiary Trusts (EBTs) and Employer Funded Retirement Benefit Schemes (EFRBSs)

We have a leading team of specialist lawyers with many years’ of experience advising companies and individuals on claims arising out of their involvement in a variety of failed tax mitigation and avoidance schemes including, in particular EFURBs and EBTs.

Our team has pursued claims against accountants who recommended EBTs and EFURBS to their clients without explaining the significant risks involved – both to the company and the individuals personally. Equally, where those advisers have failed to advise participants to take up the HMRC settlement opportunity or, indeed actively advised not to do so.

Those cases have concluded in our clients recovering substantial payments in settlement from their accountants’ insurers.

We work closely with ‘big four’ accountancy firms to not only negotiate a reduction in liability with HMRC, but also to quantify and analyse the legal claims against negligent tax advisers and accountants who recommended EBTs and EFURBs.

HMRC have recently extended the previous settlement opportunity for these schemes to 30 May 2018. After this time, we understand all settlement opportunities presently available will be withdrawn leaving participants then facing additional 30% penalties. We strongly urge anyone who has not already done so to take urgent advice on their position with HMRC and also as to a claim against their tax adviser or accountant.

It is important to note that strict time limits apply to such legal claims and after that time has passed, you will not be able to bring any claim.

This is particularly significant given the new tax legislation announced by HMRC to come into force in April 2019 which will cause the individuals who benefitted from the EFURBs or EBTs to face personal tax liability on any outstanding loans connected to those schemes. For many this will prove to be an unexpected and financially devastating event.

We represent a number national and multinational corporations, high profile individuals including City figures and well-known sports professionals. Our firm and our lawyers have both been ranked by the independent legal directories Legal 500 and Chambers & Partners in this specific field.

To discuss your specific circumstances in more detail without charge or obligation please call Julia Norris at our Manchester office.

About Us

We provide expert lawyers recommended and recognised as ‘Leading Individuals’ by Chambers & Partners who note the firm’s “pragmatic, practical and efficient approach” and “determined litigators with a very good sector knowledge” Legal 500 notes “FS Legal is a firm that punches well above its weight and is particularly strong in the areas of financial services, pensions and tax schemes” adding that the team has “a deservedly good reputation for providing a top-quality, commercial service“.

To view the Firm’s Commercial Litigation Directory Rankings please click here for Chambers & Partners and click here for Legal 500.


We understand that, whether it’s a personal or business matter, funding is a key concern. We have a variety of funding options available to seek to remove the risk and cost from our clients. Unlike most firms, we are able to operate the vast majority of our cases on a contingent (‘no win no fee’) basis.

Because professional negligence cases are intricate and require specialist knowledge, we offer a free, no obligation, and confidential advice service to all our new clients.


To view our press coverage regarding tax avoidance schemes including commentary in the Financial Times, please follow the below links our visit our Press Centre:

FT – ‘Tsunami’ of claims after crackdown creates £5bn tax bill

FT – Taxmen challenge film fund partners

FT – Stars face big bill as tax plan backfires

FT – Film backers face unhappy tax ending

Mail on Sunday – Some of Britains biggest celebrities urged claim failed tax avoidance schemes

FT Adviser.com – Tax avoidance compensation could hit advisers