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More about the Loan Charge

Jim Harra’s responses to specific questions asked by the Treasury Select Committee about the Loan Charge are, at least in part, a masterpiece in Yes Minister-style obfuscation, writes David Pett (Temple Tax Chambers).

Those with an interest in ITEPA 2003 Part 7A (the disguised remuneration or ‘DR’ rules) and the loan charge on employees directors and contractors who at 5 April 2019 had outstanding loans made to them by an employees’ trust or other third party (‘the Loan Charge’) should read a recent exchange of letters between (now) Dame Harriet Baldwin MP Chair of the Parliamentary Treasury Committee and Jim Harra the Chief Executive of HMRC.

A letter from Chair of the Treasury Select Committee to Jim Harra dated 5 February 2024 (see bit.ly/TreasuryCommitteeLetter) requested answers to further questions on the settlement of tax balances related to the...

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