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DISGUISED-REMUNERATION


David Pett (Temple Tax Chambers) looks at the information requirements and how the disguised remuneration rules apply to the loan charge, and to later steps, if no settlement of earlier liabilities has been made with HMRC.
Gideon Sanitt (Macfarlanes) considers the human rights challenge by the Loan Charge Action Group against rules taxing historical employment related loans that are outstanding on 5 April 2019.
There are provisions tackling disguised remuneration in the Finance Act 2017, the Finance Bill currently going through Parliament, and for inclusion in the next Finance Bill. Liz Pierson (Squire Patton Boggs) reviews the legislative landscape.
 
Claire Hooper (EY) outlines the government’s plans to re-introduce measures dropped from the pre-election Finance Bill and looks at the changes made to the previous draft.
 
It seems that HMRC will finally achieve its objective of taxing all but the very oldest of loans made by EBTs by the end of 2018/19. Ashley Greenbank and Nigel Doran (Macfarlanes) explain.
 
Andrew Goldstone and Helen Cox (Mishcon de Reya) review the latest tax developments that matter affecting private clients.
 
Karen Cooper (Cooper Cavendish) reviews the proposed changes to disguised remuneration and recaps the recent changes to date.
 
Nigel Holmes (Armstrong Watson) answers questions on the references in the recent Budget to disguised remuneration and their possible impact on EBTs.
 

Keith Gregory (NGM Tax Law) answers a query on how an EBT trustee wishing to provide loan finance in connection with a joint venture development company can avoid triggering a charge under the disguised remuneration rules

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