Recent use of offshore loan schemes - anyone approached HMRC?

[EBTContractor]

With most of the assessments I've seen, HMRC has treated the loans as "other" or "foreign" income, rather than employment income, and has just charged tax not NI. Some of the post-2011 schemes got around the disguised remuneration legislation by having the users as self-employed (sole traders) rather than employees. In this case HMRC may be more likely to charge additional NI (class 4).

This I imagine makes it more appealing for people to settle these ludicrous HMRC claims as it makes it slightly more palatable, even when any new "income" pushes a person up into the next tax bracket and rapes him/her.

Regarding self-employed (sole traders), I imagine loans have come from overseas in which case they also fall under the "other" or "foreign" income category and will be NI exempt?

Post-2011 products do you mean under GAAR which came into effect in July 2013? So HMRC has to prove that a person entered into an abusive arrangement?

How can they tackle pre-2013 products?