In September 2019, the Government commissioned Sir Amyas Morse to lead the Independent Loan Charge Review. The Loan Charge is designed to tackle disguised remuneration avoidance schemes. These are tax avoidance arrangements that seek to avoid Income Tax and National Insurance Contributions by paying scheme users their income in the form of loans, usually via an offshore trust, with no expectation that the loans would ever be repaid.
On 20 December 2019, the Government published the independent review and the Government’s response, accepting all but one of the review’s recommendations (HCWS14). On 20 January 2020, HM Revenue & Customs (HMRC) published draft legislation giving effect to the changes to the Loan Charge following the review (HCWS45).
Today HMRC have published the following:
All measures will be legislated for in the forthcoming Finance Bill.