Finance Bill 2017 introduces more rules to target disguised remuneration, including a charge on all remaining untaxed loans and extending the rules to the self-employed and partners.

At Budget 2016 the Government announced a package of changes to tackle perceived abuse of the disguised remuneration rules.  Some of these were include in Finance Act 2016, including a targeted anti-avoidance rule and the withdrawal of transitional relief.

The draft Finance Bill 2017 includes most of the remaining changes announced.  The main ones being:

  • A new tax charge on all untaxed disguised remuneration loans (whenever granted) still outstanding at 5 April 2019.
    • Parties to such loans should start considering their options regarding repayment if they are to avoid a charge.
  • The extension of the disguised remuneration rules to the self employed and partners:
    • From 6 April 2017 a charge will arise if they seek to lower their trading income by diverting money which is ultimately received back as a loan or other non-taxable amount.
    • The new loan charge will also apply to self employed individuals with outstanding loans on 5 April 2019.

Finance Bill 2017 also includes measures on:

  • Loan transfers and loans to close company participators.
  • Charges arising from payments to HMRC.
  • Release of disguised remuneration loans.
  • Employer deductions.

The final measure announced in Budget 2016 (transferring liability to individual employees) will be consulted on in early 2017.


Our subscriber guide: Disguised remuneration

HMRC’s consultation documents on these changes can be found here


We hope you are enjoying this amazing Practical Tax Database here at

Sign up now to receive our unique FREE Newsletter full of Tax Planning Tips & Know-How.

.Squirrel ad