Adam Craggs and Constantine Christofi (RPC) provide a quarterly update on trends and themes in the world of contentious tax.
The 2019 loan charge and PAYE
As readers will know Finance (No. 2) Act 2017 introduced a charge on certain outstanding loans which HMRC considers to be ‘disguised remuneration’ designed to avoid tax (the loan charge). The loan charge will apply to all such loans made since 6 April 1999 if they are still outstanding on 5 April 2019. Debate continues to rage on whether the legislation is fair given that a charge will be levied on loans made up to 20 years ago – a time period normally reserved for taxpayers who have behaved deliberately or in other words fraudulently. A common complaint from taxpayers who will be caught by the loan charge is that whilst they may have utilised ineffective tax arrangements they...
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Adam Craggs and Constantine Christofi (RPC) provide a quarterly update on trends and themes in the world of contentious tax.
The 2019 loan charge and PAYE
As readers will know Finance (No. 2) Act 2017 introduced a charge on certain outstanding loans which HMRC considers to be ‘disguised remuneration’ designed to avoid tax (the loan charge). The loan charge will apply to all such loans made since 6 April 1999 if they are still outstanding on 5 April 2019. Debate continues to rage on whether the legislation is fair given that a charge will be levied on loans made up to 20 years ago – a time period normally reserved for taxpayers who have behaved deliberately or in other words fraudulently. A common complaint from taxpayers who will be caught by the loan charge is that whilst they may have utilised ineffective tax arrangements they...
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:
