Andrew Goldstone and Victoria Howarth (Mishcon de Reya) review recent developments, including consultations on VCTs, social investment tax relief and income tax allowance restrictions for non-residents; changes to the tax treatment of commercial loans taken out by non-doms; ATED; and guidance on dual employment contracts
On 4 August HMRC unexpectedly announced a major change to the taxation of commercial loans taken out by UK resident non-domiciled individuals where the borrowed money is brought to the UK.
Historically HMRC has interpreted the rules under ITA 2007 s 809L in such a way that only paying the loan interest or repaying the principal out of foreign income or gains has been taxed as remittances. Under the previous guidance in HMRC’s Residence domicile...
