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1. Introduction

1.1 The Disguised Remuneration Loan Charge (Loan fee) had been announced at Budget 2016 to tackle the application of disguised remuneration taxation avoidance schemes. They are taxation arrangements that seek in order to avoid tax and National Insurance efforts if you are paying scheme users earnings by means of loans, frequently via a overseas trust, without any expectation that the loans will ever be repaid.

1.2 The legislation introduced in 2017 suggested that outstanding balances at 5 2019 of loans taken out since 6 April 1999 would be taxed as income for the 2018 to 2019 tax year april. Taxpayers wouldn’t be liable when they repaid the mortgage or settled their affairs with HM Revenue and Customs (HMRC ) before that date.

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