2019 Loan Charge why is it needed

The request was successful.

Dear HM Revenue and Customs,

HMRC and Rt Hon Mel Stride have often stated that the tax was always due on the arrangements which are now caught by the 2019 Loan Charge. Can you please tell me under which part of tax legislation was tax due on these arrangements from 1999 to date.

Yours faithfully,

Mark Watkinson

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

Our ref: FOI2019/00794

Dear Mr Watkinson,

Freedom of Information Act 2000 Acknowledgement

Thank you for your communication of 27th March which has been passed to
HMRC's Freedom of Information Team.

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Yours sincerely

HMRC Freedom of Information Act Team

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

1 Attachment

Dear Mr Watkinson,

I am writing in response to your request for information, received 27th
March.

Yours sincerely,

HMRC Freedom of Information Team