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Disguised remuneration and the loan charge rules

11 July 2018 / David Graham , Dave Jennings
Issue: 4655 / Categories: Comment & Analysis

Loans, legislation and liabilities


  • The 5 April 2019 loan charge will apply to third-party employment loans made since 6 April 1999.
  • Details may have to be reported to HMRC even if the loans have been repaid.
  • There are other options: settle with HMRC before 5 April 2019 or repay the loans.
  • HMRC must be approached with information before 30 September 2018 if settlement is sought before the loan charge applies.

There has been much coverage of the Supreme Court’s decision in RFC 2012 plc (in liquidation) – formerly The Rangers Football Club PLC (2017) UKSC 45. Generally the views of advisers and HMRC towards employee benefit trusts (EBTs) – and for EBTs also read employer-financed retirement benefits schemes (EFRBS) and various other titled trusts or third party vehicles – have changed considerably over the years and this includes...

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