Loan Charge APPG invite – January 2020


Andy Wood

Andy is a practical, creative tax adviser who assists a variety of clients in achieving their personal and commercial objectives in the most tax efficient manner.

General – Loan Charge Invite

ETC Director, Andy Wood, was invited to meet with the Loan Charge All Party Parliamentary Group (“APPG”) on Monday 20th of January.

Sadly, due to the late notice, he was unable to attend. However, as an alternative, he sent a written response to the Sir Amyas Morse led review of the loan charge.

The written response sets out three key points that ETC wished to make in relation to Sir Amyas’ review:

  1. revising the loan charge such that it only applies to advances made after 9 December 2010 on the basis that this is the date the law became ‘clear’ is, at the very least, highly arguable (“Was the law clear?”);
  1. The loan charge is totally ineffective in addressing ongoing contractor loan schemes (“The loan charge does not address existing schemes”); and
  1. My recommendation to curtail the promotion of such schemes is to introduce a transfer of a PAYE liability from an umbrella scheme to the directors and / or associates where there has been an insufficiency of tax (“Provisions allowing transfer of liability”)

You can read the note in full here at ETC written response to APPG invite.

Who are the Loan Charge APPG?

The Loan Charge APPG was created to bring together parliamentarians of all flavours from both Houses who have concerns about the nature and impact of the ‘2019 Loan Charge’.

More information can be found on this organisation by visiting their website here.

Our full response to Sir Amyas’ review

If you wish to read our full review of Sir Amyas’ report in to the loan charge then this can be found here and here.


If you or your clients have any queries about this written submission to the APPG, or the loan charge more generally, then please do not hesitate to get in touch.


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