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The way I read this paragraph 2.6 is that in order to benefit from the new Loan Charge terms, you must first settle your pre 2010, and then it clearly says the pre-2010 loans are not benefiting from the new terms
2.6 Where individuals have both loan charge liabilities and disguised remuneration liabilities that are not subject to the loan charge, they will need to settle all of their disguised remuneration avoidance with HMRC in order to access the settlement opportunity. Only the liabilities that are within scope of the loan charge will benefit from the concessions available under the settlement opportunity.
My accountant advised that the loan charge review only deal's with the loan charge as it now exists. Pre 2010 loans are no longer within its scope so excluded from the recommendations. He also said he'd be amazed if new settlement offers weren't fortcoming ..... except it's HMRC.
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