Specific rules were introduced by F(No 2)A 20171 to deal with the disguised profit rules (B2.225) in relation to loans or quasi-loans made before 6 April 2017 (but on or after 9 December 2010) that remained outstanding immediately before the end of 5 April 20191.
The rules closely mirror the disguised remuneration rules discussed at E4.1059. The discussion below refers back to this commentary on the disguised remuneration rules where appropriate and only looks in detail at those parts which do not directly use the disguised remuneration concepts and definitions.
Where the rules applied, a loan or quasi-loan was to be treated as a 'relevant benefit' and therefore taxed as trading profit. A loan was defined in identical terms2 (with minor drafting changes) as was it for the disguised remuneration rules, see E4.10593.
The amount of the relevant benefit was treated as profits of the trade for 2018/19 or if the trader had ceased to carry on the trade it was treated
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