Advice for Sanzar Solutions EBT scheme users

Sanzar Solutions

Sanzar Solutions and Sanzar Partnership Trust users scour the web for advice as thousands of contractors receive Accelerated Payment Notices (APNs) from HMRC. What should contractors do? Is the contractor loan settlement opportunity still relevant? What to consider once in receipt of an APN?

A bit about Sanzar Solutions Isle of Man (IOM) Partnership EBT Scheme

Sanzar Partnership Trust Limited which was a contractor pay scheme arrangement involving an Employment Benefit Trust (EBT) came to an end on 5 April 2009. This morphed into a new scheme namely Sanzar Solutions (which also involved trust arrangements). These trust arrangements have inheritance tax implications.

This blog will also be of interest to you if you were with Darwin Pay, Darwin Partnership, IQ Consultants and Garraway Consultants Limited which are all run by the same promoter of Sanzar Solutions and Sanzar Partnership and are all being investigated by HMRC.

Is the Contractor Loan Settlement Opportunity (CLSO) still relevant to Sanzar participants?

The answer is: Not for many. But EVERYONE who has used this tax scheme should engage with HMRC about this option before 30 JUNE 2015. 


  1. It leaves your options open.
  2. The Settlement Opportunity (SO) might exclude certain years completely if there is no open appeal against a discovery assessment or enquiry into a tax return for the relevant year.
  3. Your loans are treated as income under the Transfer of Assets Abroad (which means you are taxed on your loans and not your invoice value)
  4. You will avoid National Insurance altogether which may not be the case later.
  5. Most importantly, no penalties guaranteed and these could be as much as twice the tax in certain circumstances.

Contractors (whether you are an IT, Financial or any other contractor), you now only have 3 weeks from the date of this article to do it!

Have you received your Accelerated Payment Notices (APNs)?

Sanzar users who have received their APNs now have less than 90 days to pay up.

As tax specialists we advise that you consider the following:

  • Is your APN legal? 
  • Is your APN correct?
  • Have you considered what would happen if you don't pay within the time limit?
  • Have you made representations to HMRC?
  • Are you entitled to an additional 30 days to pay?
  • Do you know what the penalties are for not paying on time?
  • Are you going to challenge HMRC's position on Sanzar Solutions?
  • Do you think you need a tax investigation specialist handling this for you?

If you need to speak to a tax investigation specialist please call us on 02089582653 or contact us here.