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Delays to Making Tax Digital

During the 2015 Budget, the government announced their vision of revolutionising the tax system, and turning HM Revenue & Customs into one of the foremost technologically-advanced tax administrations in the world. With pressure mounting on the department to address the frustrating and often inefficient exercise of administering and paying taxes, coupled with the population increasingly choosing to manage their lives online (from shopping to banking) thanks to the proliferation of smart phone and tablet use, the motivation and benefits of moving the tax system online are clear. Later in 2015, HMRC released the Making Tax Digital Roadmap which set out the reasons for overhauling the system, the changes required to bring the system online, and an insight into how the changes would be implemented and fully operational by 2020. Read more

Part 7A Loan Charge – How will April 2019 affect your clients? – Part Three: Early Settlement

Part 3 of 4 – Should early settlement with HMRC now be considered?


In this week’s article, given the content of the previous two parts of this article which can be read here, and in the light of the decision for HMRC at the Supreme Court against Murray Group Holdings, we look at whether settling with HMRC should now be considered by clients who expect to receive an April 2019 loan charge.

We understand that HMRC are in the process of deciding how to apply the Murray Group Holdings case and we assume we shall find out shortly. However, it seems highly likely that Follower Notices will be issued to participants of most EBT/EFRBS arrangements (irrespective of any factual differences between the arrangements) and, even if there were differences, would anyone be willing, or rich enough, to risk a 50% penalty by challenging them. Read more

Part 7A Loan Charge – How will April 2019 affect your clients? – Part Two: Examples

Part 2 of 4 – Examples


Following on from Part One of this series of articles which can be read here, we look this week at some examples of how the legislation might be applied in practice.
Experience tells us that legislation is almost always more easily understood when looking through some examples of how the particular legislation is actually or could be applied in practice. What we endeavour to do in in this article is to present some scenarios that are likely to be common and could affect most companies and their employees who have participated in EBTs, EFRBS, and/or other such employee reward structures that might now fall within the Part 7A charge and be caught by the April 2019 charge. Read more

Part 7A Loan Charge – How will April 2019 affect your clients? – Part One

Part 1 of 4 – Background and The Charge


We have all known for some time now that come April 2019 most loans from a disguised remuneration’ structure or scheme, not repaid by this date, will become chargeable to tax. The charge to tax will be issued in the first instance to the employer, with whom the responsibility to deduct the PAYE lies, but, HMRC are also currently working on new rules which will allow them to pass any unpaid charge over to the individuals who benefitted if the employer is not able to pay or the employing company is no longer in existence. Read more

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