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When the loan charge bites: calculations and information requirements

Speed read
Sections 554Z11B–554Z11G mitigate against ‘double taxation’ if a relevant step is taken within the disguised remuneration (DR) rules, and there have been earlier unpaid DR or ‘re-directed earnings’ charges. These rules afford credit, for tax paid on that relevant step, against earlier tax charges (whether or not HMRC is in time to recover them), but only insofar as the amounts on which those earlier charges arose overlap with the amount on which the later charge arises. They are less generous than those (in ITEPA 2003 s 554Z5) which apply to relevant steps taken after settlement has been reached with HMRC or income tax on the earlier liability in respect of the same money or asset has been paid in full or is not yet payable.

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