The Government published Sir Amyas Morse’s independent review of the Loan Charge on 20 December, alongside the Government’s response to his recommendations. The Government welcomes Sir Amyas’s recognition that Disguised Remuneration schemes are a form of tax avoidance and that it was right for the Government to take action to ensure the tax was collected.
Sir Amyas’s careful and considered report examines the question of from when the Loan Charge should apply. He concludes that from 9 December 2010 the law about the tax treatment of loan schemes was clear and that the Loan Charge should apply from this date.
The Government accepts Sir Amyas’s clear view on this point and intends to legislate to implement all but one of the recommendations in the next Finance Bill.