In 2011 legislation closed the most ambiguous areas of EBT use and HMRC subsequently set a deadline for employers to agree a settlement for disputed tax .
The HMRC 's website concedes that HMRC loses 20 % of avoidance scheme litigation in court .
In 2011 legislation closed the most ambiguous areas of EBT use and HMRC subsequently set a deadline for employers to agree a settlement for disputed tax , although the authority 's website concedes that it loses 20 % of avoidance scheme litigation in court .