Solutions 
Employer-Financed Retirement Benefit Scheme (EFRBS)
An EFRBS can be used to provide retirement benefits to senior executives without the limitations imposed by an approved scheme. The EFRBS has frequently been used to provide a further cash “bonus” with a deferral of the tax charge on the employee until benefits are taken. Contributions can be made into an offshore trust to allow income and gains to build up tax-free.
Currently an EFRBS can provide significant tax deferral opportunities for an employee although the employer will not obtain a tax deduction until the benefits are taken by the employee.
The Government has indicated it wishes to legislate against some aspects of EFRBS schemes in 2011. There are no further details at present or any indication as to whether the legislation will be retrospective.