If a loan is a "loan" it cannot be taxable - true or false?

[dammit chloe]

Invoking the 20-year limit is pretty serious, so I would be surprised if they would do that without giving any justification.

I don't know the details as I haven't spoken directly to the person involved. However it concerned closed pre-2010 years and was after the SAM report.

[DealorNoDeal]

I don't know the details as I haven't spoken directly to the person involved. However it concerned closed pre-2010 years and was after the SAM report.

For 2009/10, they could use this if there has been a failure to disclose a notifiable scheme.
CH54000 - Compliance Handbook - HMRC internal manual - GOV.UK

For 2008/9, and earlier, it would have to be something else.

[dammit chloe]

For 2009/10, they could use this if there has been a failure to disclose a notifiable scheme.
CH54000 - Compliance Handbook - HMRC internal manual - GOV.UK

For 2008/9, and earlier, it would have to be something else.

Probably earlier. Don't know the person well enough to ask for more details.

[DealorNoDeal]

Probably earlier. Don't know the person well enough to ask for more details.

It wouldn't surprise me if HMRC tried it on, possibly with a few "guinea pigs". They wouldn't have much to lose and, if they could get the 20 years to stick, they could deploy this more widely. It wouldn't even matter to them if it took until say 2023 to cement this because they'd still be able to go back to 2003.

I'd be surprised, though, if they started issuing 20-year discos en masse, which would attract a lot of attention.