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Warning: there can be adverse consequences to breaking new regulations on loans to participators
KEY POINTS
- Trustees and partnerships are confirmed as relevant persons.
- Indirect loans will also be caught by a charge equivalent to that under CTA 2010 s 455.
- The 30-day rule prevents “bed and breakfasting”.
- Arrangements resulting in further loans to participators will also be subject to a tax charge.
- More changes may well be on the horizon.
In one of the more surprising moves in this year’s Budget the government introduced legislation for arrangements which are seen to abuse the rules on CTA 2010 s 455 (see FA 2013 s 79 and Sch 30). This area has never fallen short of HMRC’s interest.
When I started in HMRC over 20 years ago it was on the “hit list” – and it still is with an...
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