HMRC were using APN's before that ruling. So HMRC are no better off.
Everyone expected the loan schemes to be made illegal. Prospectively.....
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Reply to: Loan schemes ruled ‘abusive’
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Previously on "Loan schemes ruled ‘abusive’"
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Originally posted by AtW View PostAndrew Robins explains why two recent GAAR rulings are important for users and promoters of loan schemes designed to be used by contractors and employees.
What is GAAR?
In July 2013, the government introduced a new ‘general anti-abuse rule’ (GAAR) to attack ‘abusive’ tax arrangements aiming to take advantage of loopholes in the tax law by, for example, inserting artificial steps into a commercial arrangement. The GAAR only applies to actions undertaken after its commencement.
GAAR opinions
The GAAR panel has published two rulings affecting arrangements concerning loans provided in place of salary, which were designed to get around the ‘disguised remuneration’ rules. In both cases, the taxpayer (tax not payer - AtW’s comment) lost
Loan schemes ruled ‘abusive’ | AccountingWEB
Oh dear - I thought loan schemes were legal?

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Loan schemes ruled ‘abusive’
Andrew Robins explains why two recent GAAR rulings are important for users and promoters of loan schemes designed to be used by contractors and employees.
What is GAAR?
In July 2013, the government introduced a new ‘general anti-abuse rule’ (GAAR) to attack ‘abusive’ tax arrangements aiming to take advantage of loopholes in the tax law by, for example, inserting artificial steps into a commercial arrangement. The GAAR only applies to actions undertaken after its commencement.
GAAR opinions
The GAAR panel has published two rulings affecting arrangements concerning loans provided in place of salary, which were designed to get around the ‘disguised remuneration’ rules. In both cases, the taxpayer (tax not payer - AtW’s comment) lost
Loan schemes ruled ‘abusive’ | AccountingWEB
Oh dear - I thought loan schemes were legal?
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