Failed 'cleansing' scheme results in loan charge
In Grand Smile Design Limited v HMRC [2026] TC10000, the First Tier Tribunal (FTT) found that a Disguised Remuneration quasi-loan had not been repaid by 5 April 2019 despite the taxpayer using a loan 'cleansing' scheme. A transfer of shares to settle the outstanding amount was not a 'payment' and the loan charge applied.
