The disguised remuneration rules to be introduced under the Finance Act 2011 are acknowledged by the Government to be complex. The legislation is deliberately drafted to catch more than the Government intended, namely EBTs and EFURBs considered to be abusive. Although numerous exclusions seek to allow normal business activity to continue unhindered, businesses will need to check they are not caught by the new rules. The rules are expected to produce some inequitable results. The attached note seeks to provide a guide to the new rules, with some analysis. The note is based on the draft rules as amended at the Committee stage. Once the Finance Bill becomes law later this summer, the note will be updated.