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Commercial loan concession axed

HMRC have withdrawn the concessional treatment for commercial loan arrangements where unremitted foreign income or gain is used as collateral.
Money brought to or used in the UK under a loan facility secured by foreign income or gains will be treated from 4 August as a taxable remittance of the amount of foreign income or gains.
If the loan is serviced or repaid from different foreign income or gains, the repayments of capital and interest will constitute remittances in the normal way.
Revenue officials say the change was made after they saw large numbers of arrangements they did not consider to be …

Read more here: Taxation

HMRC to appeal Rangers tax case defeat

Accountancy Age

HM REVENUE & CUSTOMS has sought leave to appeal against a tax ruling over Glasgow Rangers’ use of an employee benefits trust to remunerate its players and staff. Last month, HMRC was defeated in an upper-tier tax tribunal which upheld a first-tier ruling that the corporate entity which formerly housed Rangers, now in liquidation (oldco), had legitimately used the scheme between 2001 and 2010 to pay £47.65m to players and staff in tax-free loans….

Read more here: Accountancy Age

Non-dom loan rule change set to cause disputes

Accountancy Age

NON-DOMICILES could be set to clash with HM Revenue & Customs over plans for its treatment of loans secured by non-doms using foreign income and gains, the CIoT has warned. The government announced this week it was withdrawing its current treatment for commercial loan arrangements secured using unremitted foreign income or gains as collateral for a loan enjoyed in the UK. HMRC said this was because it was seeing large numbers of arrangements…

Read more here: Accountancy Age