loan charge

Budget 2020 – The Usual Suspects

You would have thought that after, what, 10 years of specific anti-avoidance legislation HMRC would have cracked the tax avoidance nut. But no, the latest proposals in Budget 2020 would suggest that HMRC think otherwise. As the Budget ‘Red Book’...

‘Twas the afternoon before Christmas

If such a thing even exists, the Friday afternoon before the Christmas Break is rarely an exciting or memorable occasion in the tax world. Not like 31 January, say, or the morning before the Budget announcement, when minds are sharp...

The 2019 DR Loan Charge – Act now!

For participants in what HMRC calls Disguised Remuneration tax avoidance, we previously reported in August 2018 the details of what is the final settlement opportunity. The “carrot” was stated to be resolution and finality of long standing investigations with the...

HMRC ramps up pressure on EBTs

The expectation that HMRC would use the Supreme Court’s decision in the Rangers Case as the basis of issuing Follower Notices and Accelerated Payment Notices has now become a reality.  As set out in our previous blog HMRC is required...

2019 Loan Charge – another weapon for HMRC

If you have used remuneration tax planning involving loans (after 6 April 1999) and choose not to settle with HMRC using the current disguised remuneration settlement opportunity, then any outstanding loans as at 5 April 2019 will be subject to...

Settling disguised remuneration arrangements

In August last year we reported on the announcement of HMRC’s final settlement opportunity for Employee Benefit Trust (EBT) users as a result of the infamous Rangers decision in the Supreme Court. This settlement opportunity is also for Employer Financed...