Francis Wilks & Jones

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Francis Wilks & Jones

8 Contributions by Francis Wilks & Jones Experts

Disguised remuneration (UK): evolution from EBT/EFRBS planning to Part 7A, Rangers, loan charge and 2025 review; extension to the self‑employed (2003–2026)
PRACTICE NOTES
FORTHCOMING CHANGE: Following the Autumn Budget 2024 announcement, the government initiated an independent review into the loan charge in question. Formally launched on 23 January 2025, the review’s brief was to examine, in particular, obstacles stopping those still affected by the loan charge, who have yet to settle and pay their tax liabilities in full, from reaching agreement with HMRC, and to recommend how they might be encouraged to reach settlement with HMRC (see News Analysis: Autumn Budget 2024—Independent review of the loan charge). To support this work, a call for evidence aimed at individuals remaining within the scope of the loan charge, and their advisers, was issued on 28 March 2025. The review’s Final Report, together with the government response, was released at Budget 2025 on 26 November 2025...
Tax
Disguised remuneration loan charge (UK): evolution, key reforms, litigation and settlement routes – from Rangers and Morse to the 2025 independent review and Finance Bill 2026
PRACTICE NOTES
FORTHCOMING CHANGE: Following the Autumn Budget 2024, the government set up an independent examination of the loan charge to review its operation and practical impact. Formally unveiled on 23 January 2025, the review’s remit was to ‘examine the barriers preventing those who are subject to the loan charge but have not already settled and paid their tax liabilities in full from reaching resolution with HMRC’ and to ‘recommend ways in which they can be encouraged to settle with HMRC’ (see News Analysis: Autumn Budget 2024—Independent review of the loan charge). To support this work, a call for evidence directed at individuals still within scope of the loan charge (and their advisers) was issued on 28 March 2025 for public consultation. The Final Report, together with the government’s response, appeared at Budget 2025 on 26 November 2025. In addition, the report concluded that the loan charge
Tax
ITEPA 2003 Part 7A (UK): relevant steps in disguised remuneration—earmarking, payments and loans, asset availability, leases; reversal relief, DOTAS and GAAR
PRACTICE NOTES
FORTHCOMING CHANGE: As outlined in Autumn Budget 2024, the government has commissioned an independent review of the loan charge. Announced on 23 January 2025, the review will explore the obstacles that prevent individuals subject to the loan charge, who have not yet settled and paid their tax liabilities in full, from achieving resolution with HMRC, and will set out ways to encourage them to settle with HMRC. To support this work, a call for evidence, directed at those still within the scope of the loan charge (and their advisers), was issued on 28 March 2025. The review’s conclusions, together with recommendations, will be reported and presented to the Exchequer Secretary to the Treasury by Summer 2025. For further details on the review, see News Analysis: Autumn Budget 2024—Independent review of the loan charge. HMRC has also confirmed the operational activity it will carry out while the
Tax
Self‑employed disguised remuneration (UK): rules, Conditions A–E, loan charge, FA 2020 changes and the new settlement scheme (Finance Bill 2026)
PRACTICE NOTES
FORTHCOMING CHANGE: Following the Autumn Budget 2024, the government instructed an independent examination of the loan charge, commissioning a review. Announced on 23 January 2025, its remit was to identify the barriers preventing people within the scope of the loan charge who have not already settled and paid their tax liabilities in full from reaching a final resolution with HMRC, and to outline recommendations on how they might be encouraged to settle with HMRC (see News Analysis: Autumn Budget 2024—Independent review of the loan charge). To support the review process, a call for evidence, targeted at those still subject to the loan charge (and their advisers), was issued on 28 March 2025. The Final Report of the review, together with the government response, was released at Budget 2025 on 26 November 2025. It concluded that the loan charge had failed as a
Tax
UK disguised remuneration (ITEPA 2003 Part 7A): exclusions, reliefs and loan charge carve-outs for employee share schemes, deferred remuneration and employment-related securities
PRACTICE NOTES
STOP PRESS: Abolition of non-dom regime and remittance basis of taxation from 2025–26 From 6 April 2025, the Finance Act 2025 abolishes the remittance basis of taxation and introduces a residence-based approach. The reforms include a new Foreign Income and Gains (FIG) regime, alongside changes to overseas workday relief. For further details, see Practice Note: The abolition of the remittance basis of taxation from 2025–26. FORTHCOMING CHANGE: As set out at Autumn Budget 2024, the government commissioned an independent review of the loan charge. Announced on 23 January 2025, the review will consider barriers preventing those subject to the loan charge who have not settled and paid their tax liabilities in full from reaching resolution with HMRC, and will recommend ways to encourage settlement with HMRC (see News Analysis: Autumn Budget 2024—Independent review of the loan charge). To inform the review, a call for evidence aimed at those
Tax
UK disguised remuneration (ITEPA 2003 Part 7A): gateways, relevant steps, close companies, DOTAS/GAAR, and loan charge review and settlement scheme developments
PRACTICE NOTES
FORTHCOMING CHANGE: Following the Autumn Budget 2024, the government initiated an independent review into the loan charge. Launched on 23 January 2025, the review’s remit was to examine the obstacles preventing people within scope of the loan charge, who have not settled and paid their tax liabilities in full, from reaching agreement with HMRC, and to recommend measures to encourage settlement with HMRC (see News Analysis: Autumn Budget 2024—Independent review of the loan charge). To support this work, a call for evidence—directed at those still affected by the loan charge and their advisers—was issued on 28 March 2025. The Final Report, together with the government’s response, was released at Budget 2025 on 26 November 2025...
Tax
UK disguised remuneration (ITEPA 2003 Part 7A): valuation, reliefs, loan charge, remittance basis, PAYE and NICs, and liability for payment
PRACTICE NOTES
STOP PRESS: Abolition of non-dom regime and remittance basis of taxation from 2025–26 From 6 April 2025, the Finance Act 2025 abolishes the remittance basis of taxation and replaces it with a residence-based regime. The package introduces a new Foreign Income and Gains (FIG) regime and updates the rules on overseas workday relief. For more on these changes, see Practice Note: The abolition of the remittance basis of taxation from 2025–26. FORTHCOMING CHANGE: As flagged at Autumn Budget 2024, the government commissioned an independent review of the loan charge. Announced on 23 January 2025, the review was to examine barriers preventing those subject to the loan charge, who have not already settled and paid their tax liabilities in full, from achieving resolution with HMRC, and to recommend how they might be encouraged to settle with HMRC (see News Analysis: Autumn Budget
Tax
UK disguised remuneration (Part 7A): regime overview, gateway and relevant steps; EBTs, pensions and share schemes; loan charge review and 2025–26 settlement reforms
PRACTICE NOTES
FORTHCOMING CHANGE As trailed in the Autumn Budget 2024, the government set up an independent review of the loan charge. Formally launched on 23 January 2025, the review’s remit was to examine the obstacles preventing those subject to the loan charge, who have not already settled and paid their tax liabilities in full, from reaching a resolution with HMRC, and to propose ways in which they could be encouraged to settle with HMRC (see News Analysis: Autumn Budget 2024—Independent review of the loan charge). To aid the review, an official call for evidence, directed at individuals who remain within the loan charge (and their advisers), was also subsequently published on 28 March 2025. The Final Report of the review, alongside the government’s response, was formally issued at Budget 2025 on 26 November 2025...
Tax
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