Commentary

E1.405B Disguised interest

Personal and employment tax

E1.405B Disguised interest

E1.405B Disguised interest

An income tax charge is imposed on 'disguised interest'1. This does not apply where arrangements pre-date 6 April 2013 and neither the rules relating to guaranteed returns from futures and options nor those relating to manufactured interest applied2. The charge also does not apply if the disguised interest is chargeable to income tax under another provision, or would be but for an exemption. However, it takes precedence over charges to other taxes, the legislation permitting just and reasonable adjustments to be made in respect of that other tax, notwithstanding any time limits, in order to avoid any

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial