Andrew Goldstone and Victoria Howarth (Mishcon de Reya) review recent developments, including consultations on VCTs, social investment tax relief and income tax allowance restrictions for non-residents; changes to the tax treatment of commercial loans taken out by non-doms; ATED; and guidance on dual employment contracts
On 4 August HMRC unexpectedly announced a major change to the taxation of commercial loans taken out by UK resident non-domiciled individuals where the borrowed money is brought to the UK.
Historically HMRC has interpreted the rules under ITA 2007 s 809L in such a way that only paying the loan interest or repaying the principal out of foreign income or gains has been taxed as remittances. Under the previous guidance in HMRC’s Residence domicile and...
