Paying employees through loans and trusts to avoid tax will be forbidden in most cases under new draft guidance on disguised remuneration provisions published by HMRC.A new schedule in the Finance (No. 3) Bill 2011 will treat loans, money or other assets held in trust but linked to an individual as PAYE income. HMRC also plans to bring forward a similar treatment for NICs. The regime came into effect on 6 April 2011, but will apply in some cases dating back to 9 December 2010.HMRC plans to publish final guidance as part of the Employment Income Manual in the autumn.