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Loan charge
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Loan charge
LOAN-CHARGE
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.
Comment: Why the loan charge is unfair
Keith Gordon
The loan charge has driven a coach and horses through the statutory safeguards, writes barrister Keith Gordon (Temple Tax Chambers).
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EDITOR'S PICK
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
1 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
2 /7
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
3 /7
Mandatory agent registration: what we know so far
Jane Mellor
4 /7
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
5 /7
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
6 /7
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
7 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
Mandatory agent registration: what we know so far
Jane Mellor
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
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Staggered roll-out for mandatory tax adviser registration
Consultation on proposed UK corporate re-domiciliation regime
Cryptoassets taxation: stablecoins
Administrative change to CIR rules
NIC regs mirror tax changes
CASES
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HMRC v Colchester Institute Corporation
HMRC v Boehringer Ingelheim Ltd
R (oao Rokos) v HMRC
Other cases that caught our eye: 10 April 2026
HMRC v C Brzezicki
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Exceptional circumstances – but which way?
Tax agent registration and financial services
Provisions
New SDLT burden for private renters
Transactions in Securities counteraction notices
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J Hosking v HMRC
Exceptional circumstances – but which way?
Countrywide Partners Ltd v HMRC
Muller UK and Ireland Group LLP and others v HMRC
Consultation tracker