Employee Beneficiary Trusts – Tax Mitigation

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 investors on claims arising out of their involvement in a variety of failed tax mitigation and avoidance schemes including, in particular, Employee Beneficiary Trusts (EBTs) and Employer Funded Retirement Benefit Schemes (EFRBSs).


HMRC have been challenging the tax treatment of EBTs and EFRBSs for a long time and indeed the judgement in the Rangers/Murray Group Holdings case found in favour of HMRC.

Whilst this finding is under appeal to the Supreme Court, it is advisable for all businesses and individuals with EBTs to review their position.

To encourage taxpayers to resolve their EBT issues, HMRC introduced the EBT Settlement Opportunity (EBTSO) in April 2011.

Later the EFRBS Settlement Opportunity (EFRBSSO) was opened to facilitate the settlement of the legacy EFRBS cases.

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

Having relied upon the advice of financial or tax advisers with regard to schemes such as this, participants have the option to seek reimbursement for any unexpected tax liabilities from their advisers. This is typically met by that adviser’s insurance.

To discuss your specific circumstances and potential claim in more detail please call Kit Sorrell or Julia Norris at our Manchester office.

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 around 90% of our cases on a contingent 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:

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