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

Substantial shareholding exemption ― overview

Substantial shareholding exemption ― overviewThe substantial shareholdings exemption (SSE) provides a complete exemption from the liability to corporation tax on the gains generated from qualifying disposals of shares and interests in shares by qualifying companies. No claim is required. Provided

14 Jul 2020 13:44 | Produced by Tolley Read more Read more

Taxation of loan relationships

Taxation of loan relationshipsThe vast majority of companies will have loan relationships and so will need to consider how they are taxed under the loan relationship rules. There are also specific provisions dealing with relevant non-lending relationships and other deemed loan relationships.

14 Jul 2020 13:48 | Produced by Tolley Read more Read more

Capital allowances on cars

Capital allowances on carsSummary of capital allowances on carsThe current capital allowance rates applicable to cars are as follows:Pool typeDescription of carRateLegislationMain rate poolNew and unused cars with CO2 emissions of 50g/km and below 18%CAA 2001, s 104AASecondhand cars with CO2

14 Jul 2020 11:08 | Produced by Tolley Read more Read more