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HMRC Briefing Paper - New CEST and No Historic Enquiries using SDS Data
The only naivety in the loan charge debacle was anyone thinking they would get away with it.
The conflation of IR35 and Loan Charge is misleading. They are two mutually exclusive concepts and should be treated as such.
yes, they shouldn't be connected. However, it's clear that HMRC's behaviour over the loan charge should be thoroughly investigated, which is what the enquiry should be doing, but I have my misgivings.
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