Taxation logo taxation mission text

Since 1927 the leading authority on tax law, practice and administration

The Loan Ranger

08 November 2016 / Nigel Holmes
Issue: 4575 / Categories: Comment & Analysis

The current state of play on the taxation of loans from employment benefit trusts and the action that should be considered.


  • The initial popularity of employment benefit trusts and loans was brought to an end by ITEPA 2003 Part 7A.
  • Budget 2016 announced that loans would become taxable on 5 April 2019 if not already taxed or repaid by that date.
  • Loans made before 6 April 1999 are not caught but those provided after this date replacing earlier ones are.
  • It seems that taxpayers have three options: repay settle or wait.
  • Much confusion has arisen over the interaction with inheritance tax.
  • HMRC needs to provide a carrot to taxpayers to encourage settlement.

As we await the decision of the Supreme Court on the appeal of the liquidators in the Murray Group Holdings case (CS [2015] CSIH 77) HMRC has been focusing its attention on...

If you or your firm subscribes to, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.

back to top icon