17 Loan charge reduced where underlying liability disclosed but unenforceable
Finance Act 2020 (2020 c 14) | Legislation

17  Loan charge reduced where underlying liability disclosed but unenforceable

(1)     In Schedule 11 to F(No 2)A 2017 (employment income provided through third parties: loans etc outstanding on 5 April 2019) after paragraph 1A (as inserted by section 16) insert—

“1B

(1)     This paragraph applies where—

(a)     a person is treated as taking a relevant step within paragraph 1 by reason of making a loan or quasi-loan,

(b)     a reasonable case could have been made that for a qualifying tax year (“the relevant year”) A was chargeable to income tax on an amount that was referable to the loan or quasi-loan,

(c)     at a time when an officer of Revenue and Customs had power to recover (from A or any other person) income tax for the relevant year in respect of that amount, a qualifying tax return or two or more qualifying tax returns of the same type taken together contained a reasonable disclosure of the loan or quasi-loan, and

(d)     as at 6 April 2019 an officer of Revenue and Customs had not taken steps to recover (from A or any other person) income tax for the relevant year in respect of that amount.

(2)     But this paragraph

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