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Interesting EBT case

https://www.bailii.org/ew/cases/EWHC/Ch/2018/2965.html

It suggests at para 76 that an EBT can be rescinded ab initio for mistake re tax avoidance planning, so that could solve the 2019 loan charge problem for some where the money justifies the costs of doing that (possibly in Geurnsey etc.):

https://www.bailii.org/ew/cases/EWHC/Ch/2018/2965.html

The mistake being the wholly unexpected Rangers redirected earnings tax charge.

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