The government’s much awaited and anticipated response to Sir Amyas Morse’s Loan Charge review (the Review) has been published, with substantial changes being made to tackle the more draconian impacts of the Loan Charge.
The impending application of the Loan Charge 2019 is causing taxpayers to assess their position and identify what they should be doing before the 5 April 2019 deadline.
The government has this month extended the deadline for registering an intention to settle from 31 May 2018 to 30 September 2018. For those affected, the Finance (No. 2) Act 2017 contains some of the most significant changes to tax legislation in recent memory (the 2019 Loan Charge).
Disguised remuneration scheme users who had an outstanding loan on 5 April 2019 are now liable to the controversial Loan Charge.
Since our first article about the 2019 Loan Charge, we have received a number of enquiries and common issues have appeared. Here we address some of the points we have experienced with clients in relation to the 2019 Loan Charge.
On 8 May 2018, Stephen Lloyd, Liberal Democrat Member of Parliament for Eastbourne, made an Early Day Motion calling for the 2019 Loan Charge (introduced under the Finance Act (No2) 2017) to be amended.
As we draw nearer to the 5 April 2019 and the implementation of the Loan Charge, a number of more convoluted Employee Benefit Trust (EBT) tax planning structures are being found to be affected and have thus drawn increasing interest from HMRC.
This article sets out an example of the types of schemes that we are seeing, how we expect HMRC will treat these schemes, the potential outcomes of such schemes and what we can do to help.
The Finance (No.2) Act 2017 (FA2), given Royal Assent in November 2017 controversially introduced the ability for HMRC to, in effect, go back 20 years to recover unpaid tax on certain trust based tax mitigation strategies.
Have you repaid loans as a result of HMRC’s Guidance pre-Loan Charge Review that you would no longer be liable for the Loan Charge for? We are launching a Judicial Review against HMRC’s decision to treat such taxpayers as committing new “relevant steps” if they now undo such repayments.