HMRC has been on the offensive for many years to ensure that all rewards from employment are properly taxed within the income tax and NICs regimes. This year’s Finance Bill makes further changes, including the introduction of a new targeted-anti avoidance rule. However, of much greater significance are the changes proposed to be enacted in the Finance Bill 2017, on which HMRC is currently consulting. These measures include: a new tax charge on all existing loans which remain outstanding on 5 April 2019; a new Part 7A gateway for schemes involving close companies; restrictions on the availability of corporation tax relief for certain Part 7A charges; and proposals to widen the circumstances in which HMRC can pursue employees for unpaid disguised remuneration tax liabilities. The proposed rules leave little room for manoeuvre, and they contribute to an ever more complex and demanding piece of legislation.
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