Loan Charge

[DealorNoDeal]

The Loan Charge applies to all loans received after Dec 2010, irrespective of whether the tax years in question are open or closed.

You could try and claim that you thought it didn't apply to closed years but you would be opening yourself up to penalties if they uncover the non-disclosure. Ignorance of the law isn't a reasonable excuse.

[eek]

To bring a year in dispute, they need to come fwd with their suspicion and proof.

The question is again: can they open now a year prior to 6y? Can they open 2014-2015 and prior when those where never open?

There must be an answer.

they keep 2018/19 open and use the fact you didn't report the loans as a demonstration of evasion rather than avoidance.

As DealorNoDeal states if ignorance is not an excuse, wilful evasion definitely isn't - and if there is evidence of evasion I think everything is completely fair game in HMRCs eyes.

It wouldn't surprise if HMRC used lack of reporting of a loan as evidence of evasion and once evidence of evasion is shown HMRC will merrily go back a long time. Heck I suspect all they would do is generate tax bills for the years in question and say proof otherwise.