Government rejects all calls to abandon the DR Loan Charge

The Treasury has finally published its response as required by the Section 95 Finance Act 2019 (FA2019). Section 95 FA 2019 was an amendment to FA 2019 which required the Chancellor to review the Disguised Remuneration Loan Charge (“Loan Charge”)....

The Value of the Independent Internal Review – COS Systems v HMRC

Back in the early 2000’s, HMRC was becoming concerned at the number of appeal cases being listed for hearing by what was then the General and Special Commissioners and, after consideration and consultation, in 2009 they introduced a new system...