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Overview of the loan charge

In 2017, legislation was introduced to impose a ‘disguised remuneration’ charge upon loans from ‘employee benefit trusts’ (EBTs), ‘Employer-Financed Retirement Benefits Schemes’ (EFRBS) and similar arrangements. This is also known as the ‘loan charge’. It originally applied to any individual who received a loan (with a few limited exceptions) via a disguised remuneration scheme on or after 6 April 1999 that was still outstanding on 5 April 2019, but its scope has been limited following the independent review of the loan charge (see below and the Outcome of the independent loan charge review guidance note).

For an introduction to disguised remuneration, see the Disguised remuneration ― overview guidance note.

This guidance note looks at some of the practical implications of the loan charge for employees and employers and how tax liabilities are to be assessed and reported.

For the practical considerations of ‘contractors’ who were in employment-based umbrella company loan arrangements, see the Low Incomes Tax Reform Group (LITRG)’s guidance.

See also The Chartered Institute of Taxation (CIOT)’s article published on 16 September