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Restrictions to the charge are welcome, but the question still arises why there should be any retrospection at all.
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.
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.