Why HMRC is looking down under for loan charge settlements

Andrew Hubbard

Most readers will be aware of the loan charge but for those who may need a refresher: if a person has a loan from a trust structure which is related in some way to his/her current or former employment the amount of the loan outstanding on 5 April 2019 is deemed to be employment income subject to tax and national insurance.

The new information (released following an FOI request and available at bit.ly/2Dxj6aA) is a geographical breakdown of the addresses of people potentially subject to the loan charge who have been written to by HMRC. What interested me was that over 1 720 of those addresses were outside the UK. Over 70 different countries appear with Australia and New Zealand topping the list.

The individuals involved were almost certainly working in the UK when they received the loans. Some of them will have been UK citizens who...

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