David Pett (Temple Tax Chambers) argues that outstanding loan charges should be pursued both as a matter of law and social policy.
The former financial secretary to the Treasury recently announced in a letter to MPs that: ‘HMRC will not apply the loan charge to a tax year where (sic) an enquiry was closed on the basis of fully disclosed information.’ I venture to suggest that this is misguided both as a matter of law and as a matter of social policy.
Taxing the economic benefits
There are two economic benefits of a loan enjoyed by the person to whom it is made:
the value of the loan in the sense that the price being paid for it (in terms of the interest rate payable) is less than the market value of such credit on the same terms. One measure of this is the difference between...
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David Pett (Temple Tax Chambers) argues that outstanding loan charges should be pursued both as a matter of law and social policy.
The former financial secretary to the Treasury recently announced in a letter to MPs that: ‘HMRC will not apply the loan charge to a tax year where (sic) an enquiry was closed on the basis of fully disclosed information.’ I venture to suggest that this is misguided both as a matter of law and as a matter of social policy.
Taxing the economic benefits
There are two economic benefits of a loan enjoyed by the person to whom it is made:
the value of the loan in the sense that the price being paid for it (in terms of the interest rate payable) is less than the market value of such credit on the same terms. One measure of this is the difference between...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
