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Disguised remuneration loan charge

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HMRC has issued guidance on how to apply for postponement of the new ‘loan charge’ for disguised remuneration loans outstanding on 5 April 2019.

HMRC has issued guidance on how to apply for postponement of the new ‘loan charge’ for disguised remuneration loans outstanding on 5 April 2019. Postponement may be possible where the loan in question is classed as a ‘qualifying fixed-term loan’, or the taxpayer has already made an accelerated payment in respect of the same loan. Applications must be made by 31 December 2018.

A ‘qualifying fixed-term loan’ must:

·         be made before 9 December 2010;

·         have a term of 10 years or less; and

·         not be an excluded loan (that is, subsequently replaced directly or indirectly by another loan, or have its terms altered to meet the 10-year requirement or change the final repayment date).

Applications can be made on form DR100, or by email or post to HMRC’s counter-avoidance team. See http://bit.ly/2EDzYfl.

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