LOAN-CHARGE

Heather Self

Heather Self (Blick Rothenberg) praises greater HMRC transparency while warning of deepening fiscal drag and policy inconsistency.

David Pett

All but one of the loan charge review’s ‘hard’ recommendations have been accepted. David Pett (Temple Tax Chambers) assesses both the review and the Government’s response – and considers the implications for affected taxpayers and the new settlement opportunity.

Undeclared company income: Cheon Fat Ltd v HMRC [2025] UKUT 287 (TCC) (4 July) concerns an application for leave to appeal against a decision of the FTT. It raises an important point of interest to many who advise small companies. Where a company has...

Disclosure of documents in loan charge case: K (oao Airedale Chemical Company Ltd) v HMRC [2025] UKUT 65 (TCC) (20 February 2025) is another case arising from the controversy about the loan charge. Following the Morse review HMRC established a scheme...

HMRC required to give evidence in judicial review case.

High Court strikes out Part 8 loan charge claims.

Freedom of information request relating to the loan charge: The particular concern of the applicant in F Thompson v Information Commissioner and another [2024] UKFTT 391 (21 May 2024) was the process under which Sir Amyas Morse was appointed to...

David Pett

Jim Harra’s responses to specific questions asked by the Treasury Select Committee about the Loan Charge are, at least in part, a masterpiece in Yes Minister-style obfuscation, writes David Pett (Temple Tax Chambers).

Appeal against HICBC penalty allowed: R Kajla v HMRC [2024] UKFTT 193 (TC) (7 March 2024) is another in what seems to be an endless procession of appeals against the high-income child benefit charge and the associated penalties. One point of interest...