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The government has made substantial amendments to the loan charge in light of Sir Amyas Morse’s review published on 20 December.
The former National Audit Office chief supported the policy in principle but concluded that it went ‘too far in undermining or overriding taxpayer protections’.
The government has accepted most of Sir Amyas’s recommendations. As a result the charge will now apply only to loans made on or after 9 December 2010 and will not apply to loans made before 6 April 2016 if use of the scheme was fully disclosed and HMRC did not open an enquiry.
Taxpayers who have not yet settled with HMRC may either provide an estimate of the tax due with their self-assessment return by 31 January 2020 or delay filing until 30 September 2020.
Legislation for the changes will be included in Finance Bill 2020 and will have effect from 20 December 2019.
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