2019 Loan Calculation

HM Revenue and Customs did not have the information requested.

Dear HM Revenue and Customs,
How will HMRC calculate the amounts subject to tax on the 2019 loan charge. I have read several articles that state that HMRC officers are being told to charge on a gross basis (ie ignoring fees charged by the entity issuing the loan).

This would seem wrong on 2 levels.
A loan is the amount received not the amount grossed up for charges
These charges will have been subject to corporation tax already (double taxation)

Please clarify HMRC's position on this.

Yours faithfully,
S Gray

foi.team@hmrc.gsi.gov.uk on behalf of FOI Central Team, HM Revenue and Customs

Our ref: FOI2018/00851

Dear Simon Gray,

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foi.team@hmrc.gsi.gov.uk on behalf of FOI Central Team, HM Revenue and Customs

1 Attachment

Dear Mr Gray

I am writing in response to your request for information, received 19
April 2018.

Yours sincerely,

HMRC Freedom of Information Team