The settlement offer is open to users of avoidance schemes involving remuneration trusts or creditor protection trusts, which were set up to avoid payment of income tax and National Insurance contributions. It does not cover employee benefit trusts or employer funded retirement benefit schemes.

Typically these scheme arrangements work by setting up a personal management company which is controlled either by the scheme user or connected party supporting the scheme. The money contributed to the remuneration trust is actually paid - often minus the 10% scheme fee - to the personal management company. This allows the scheme user full access to the funds.