Independent loan charge reviews

Produced by a Tolley Employment Tax expert
Employment Tax
Guidance

Independent loan charge reviews

Produced by a Tolley Employment Tax expert
Employment Tax
Guidance
imgtext

The ‘loan charge’ is a liability which attached to loans made to employees and directors via certain so called ‘disguised remuneration’ (DR) schemes. Liabilities which HMRC argued were due but remained unpaid at 5 April 2019 were identified as definitive liabilities by virtue of a new ‘loan charge’ legislation. See the Loan charge guidance note for further details.

However, the loan charge legislation was considered by many as unfair and, at best, something of a blunt force tool. This has led to two separate independent reviews of the loan charge, details of which are the subject of this guidance note.

2025 further loan charge review

The 2025 review has since resulted in the introduction into legislation of the loan charge settlement scheme. The scheme is effective from 5 August 2026 and applies to outstanding loan charge liabilities, including those that are subject to a previous settlement reached with HMRC at any time on or after 1 June 2021. The scheme incorporated most of the recommendations from the review. See the Loan charge guidance note for further

Continue reading the full document
To gain access to additional expert tax guidance, workflow tools, generative tax AI, and tax research, register for a free trial of Tolley+™
Powered by Tolley+™

Popular Articles

Self assessment ― amendments and corrections

Self assessment ― amendments and correctionsOnce a self assessment tax return has been filed, both HMRC and the taxpayer (or the agent) has the right to make changes to the return. There are different time limits depending on whether it is a correction by HMRC or an amendment made by the

14 Jul 2020 13:37 | Produced by Tolley Read more Read more

Subsistence expenses

Subsistence expensesIntroductionSubsistence is the amount incurred as a consequence of business travel. Typically it relates to accommodation and meal costs incurred. These amounts are allowed because they are associated with the necessary travel which is not to a permanent workplace. See the Travel

14 Jul 2020 13:43 | Produced by Tolley in association with Philip Rutherford Read more Read more

Bare trusts ― income tax and CGT

Bare trusts ― income tax and CGTThis guidance note explains how trustees of bare trusts are treated for income tax and capital gains purposes. Although a bare trust is, in equity, a type of trust, for both income tax and capital gains tax purposes its existence is transparent. This means that no tax

14 Jul 2020 15:34 | Produced by Tolley Read more Read more