HMRC will very shortly be issuing 10,000 "nudge" letters to users of EBTs reminding them of the limited time available to access the EBT Settlement Opportunity (EBTSO). The EBTSO contains a number of easements which means for most taxpayers, settlement under its terms will result in significantly lower tax and NIC to pay.
Those who chose not to use the EBTSO will still need to settle their case or seek recourse to the tax tribunals/courts. To encourage taxpayers to make a decision HMRC has privately stated to Abbey Tax that it will issue APNs to all known users of DOTAS registered EBT and EFRBSs whose case is under enquiry shortly after the EBTSO has closed in March 2015. It should be noted that compliance with an APN will still require that a case is formally settled (albeit in a less advantageous way) or be litigated say Harris & Co accountants Northampton #accountantsnorthampton
This is just one of the actions HMRC is taking to deal with the legacy of tax avoidance schemes; after all, its stated intention is to issue 43,000 APNs by 31 March 2016.