A significant amendment to the taxation of remuneration was introduced by FA 2011, Sch. 2 (inserting ITEPA 2003, Pt. 7A) to ‘tackle arrangements involving trusts or other vehicles used to reward employees that seek to avoid or defer the payment of income tax or NICs’ (sometimes described as ‘disguised remuneration’ or ‘remuneration through third parties’). Its application in the context of pensions includes the provision of earmarked retirement benefits through an EFRBS.
At this stage it might be useful to determine exactly where EFRBS sits on the taxation landscape and where Pt. 7A applies