In a recent response to a series of parliamentary questions, the government has estimated that the number of taxpayers who will be affected by the 2019 loan charge could be just 50,000.

The loan charge will apply to all outstanding Disguised Remuneration loans, e.g. loans made via company Employee Benefit Trusts (EBTs) or EBT sub-trusts, or similar via EFRBS where:

  • If the loan had been made on 5 April 2019 it would have fallen within the disguised remuneration rules;
  • The loan was made on or after 6 April 1999; and
  • The loan, or part of it, is still outstanding at 5 April 2019.

It is not clear from the government response but perhaps the figure is surprisingly low because it is expected that most loans will be repaid, or a settlement reached with HMRC, in advance of the April 2019 deadline.

The government also advised that less than 30 individuals had declared the use of a loan scheme on their 2016/17 Self-Assessment tax returns, signalling that only a very small group of individuals are now using this type of planning.


Disguised Remuneration (subscriber guide)

Disguised remuneration: applying to postpone your loan charge

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