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Morse code
The recent review by Sir Amyas Morse (tinyurl.com/lcramdec) and the related government feedback published last month (December 2019 at tinyurl.com/vhj26ob) confirmed that amendments will be made to the loan charge rules. The rules have attracted controversy ever since the original proposals were announced in 2016. In summary in response to the questions it sought to answer the review and the government response confirmed that in principle the loan charge rules were justified but the design was not proportionate and fair at least to some extent.
Background
The loan charge rules were introduced by F(No 2)A 2017 following an announcement at Budget 2016 as a means of seeking to tax any outstanding ‘loans’ (often made by trusts) that HMRC perceived as amounting to disguised remuneration for both ...
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