Print

The government has published ‘Independent Loan Charge Review summary of evidence’ which sets out the evidence provided to Sir Amyas Morse as part of the independent loan charge review undertaken in December 2019.

The ‘loan charge’ applies to all outstanding third party Disguised remuneration loans which, if they had been made on 5 April 2019, would have fallen within the disguised remuneration rules.

The evidence which resulted in these changes is very detailed and makes interesting reading.

The impact of the Disguised Remuneration and Loan charge rules

The first significant new legislation here was the Disguised Remuneration (DR) rules or Part 7A of ITEPA 2003, introduced in December 2010.

The DR rules were expanded in 2016 with the loan charge being announced to take effect in April 2019.

The effect of the Disclosure Of Tax Avoidance Scheme (DOTAS) rules, follower notices and Accelerated Payment Notices (APNs)

Off-Payroll Working and Personal Service Companies (PCSs)

Attitudes and views of scheme users affected by the Loan Charge

Submissions from the All-Party Parliamentary Group about the loan charge were considered.

HMRC powers to tackle tax avoidance and compliance action

Links

General Anti-Abuse Rule: GAAR At a glance
This note looks at the key features of the General Anti-Abuse Rule (GAAR) contained within the Finance Act 2013 and the basics of what you need to know about the provisions it contains when considering tax planning.

Disguised remuneration
An at a glance, freeview introduction to the Disguised Remuneration rules.

Disguised remuneration loan charge (subscriber guide)
What is disguised remuneration? What is the loan charge? When does the loan charge apply? Will the loan charge affect me?

Accelerated Payments & Follower Notices (subscriber)
A follower notice might be issued if you use a tax avoidance scheme with the same or similar arrangements to one that HMRC has successfully challenged in court.

FAQs for Disguised Remuneration Settlements (subscriber)
This guide looks at Frequently Asked Questions for settling Disguised Remuneration schemes.

General Anti-Abuse Rule – GAAR (subscriber)
This briefing note looks at the key features of the General Anti-Abuse Rule (GAAR) contained within the Finance Act 2013, what areas of tax it covers and what you need to know about the provisions it contains when considering tax planning.

External link

‘Independent Loan Charge Review summary of evidence’