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Loan charge
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Loan charge
LOAN-CHARGE
Comment: Why we need a new disguised remuneration settlement opportunity
Sarah Gabbai
The government should take a more pragmatic approach to taxpayers affected by
the loan charge, writes Sarah Gabbai (McDermott Will & Emery).
Private client review for January 2022
Thomas Simpson
Edward Reed
Several recent case decisions in the private client arena, including a challenge to the validity of the loan charge legislation, are examined by Edward Reed and Thomas Simpson (Macfarlanes).
Self's assessment: how do we stop the rogue promoters?
Heather Self
A call for action to help tackle the promotion of disguised remuneration avoidance schemes.
Contentious tax: quarterly review
Constantine Christofi
Adam Craggs
Your quarterly review of developments in the contentious tax world, by Adam Craggs and Constantine Christofi (RPC).
The disguised remuneration regime unpacked
Karen Cooper
Karen Cooper (Cooper Cavendish) sets out the rules, tax treatment and the impact of legislation on EBTs and remuneration planning.
Amendments to the 2019 loan charge: work in progress
David Southern QC
David Southern QC (Temple Tax Chambers) examines where things stand following publication of the first batch of draft legislation that restricts the loan charge.
The revised loan charge
Peter Vaines
Restrictions to the charge are welcome, but the question still arises why there should be any retrospection at all.
Changes to the loan charge following the Morse review
David Pett
The government has accepted many of the recommendations of Sir Amyas Morse’s independent report on the loan charge. David Pett (Temple Tax Chambers) examines the detail.
Comment: The loan charge review – where are we now?
Rhys Thomas
Rhys Thomas (WTT Consulting) welcomes restrictions to the loan charge, but argues that they don't go far enough and says a number of questions remain unaddressed.
Loan charge review: significant changes afoot
Hugh Gunson
Hugh Gunson (Charles Russell Speechlys) explains where things stand.
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3
EDITOR'S PICK
The Orsted ‘tax nothing’
Andrew Page
1 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
2 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
3 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
4 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
5 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
6 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
7 /7
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
NEWS
Read all
Conservatives pledge IHT exemption for family homes
Government accepts PAC recommendations on large business tax compliance
No breaches found under banks’ tax code
Distributions reform could hinder business transactions, CIOT warns
Bolt: Supreme Court refuses permission to appeal
CASES
Read all
HMRC v British Airways plc
Victoria Oil & Gas plc v HMRC
S Keswick and others v HMRC
Other cases that caught our eye: 9 October 2026
Jumpman Gaming Ltd v HMRC
IN BRIEF
Read all
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
Loans to participators: s 455
Modernising the taxation of distributions
MOST READ
Read all
Bolt: Supreme Court refuses permission to appeal
Re Fulmar Contracting Ltd (In Liquidation) and others v M Williams and another
HMRC name 196 deliberate tax defaulters
Victoria Oil & Gas plc v HMRC
Loans to participators: s 455