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Judicial review launched against the loan charge

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A pressure group intends to launch a judicial review against HMRC’s loan charge, which comes into effect in April 2019.

The Loan Charge Action Group has appointed tax barrister Robert Venables QC to mount a challenge on the basis that the schemes subject to the charge were mis-sold by employers and accountants. It will argue that the outstanding tax should be paid by employers rather than those working for them, and that the charge is an unfair retrospective tax.

The loan charge was introduced by F(No. 2)A 2017 to tackle disguised remuneration schemes brought within ITEPA 2003 Part 7A. A summary of the charge, produced by the CIOT’s Low Incomes Tax Reform Group, is available at

Issue: 1416
Categories: News