Contractor Loans: settlement opportunity

“Contractor Loan” planning has been around for some years.  We have never much liked it.

Last year HMRC took on and defeated a particularly egregious example of the planning in the Boyle case (see our earlier comment and article) and, flushed with success, have now published details of their “Settlement Opportunity”.  It does not offer much by way of compromise or concession: HMRC “concede” that no NIC will be payable if the Opportunity is accepted – but it is somewhat doubtful whether NIC is due anyway.  The main advantage of accepting is therefore to bring closure and certainty.  If cash resources do not permit of immediate settlement, HMRC will discuss instalment payments.

We suspect that in many cases accepting the offer will be the best way forward, though in some variants of the scheme it may be possible to put forward technical arguments to carry on the fight if you have the stomach for it.

For more, please get in touch with your usual BKL contact partner or use our enquiry form.

NICOLA HALL

BILSHAN MENSAH

Sam Inkersole

In 2022, Sam won the Taxation’s Rising Star award at the Taxation Awards in and was named in the Accountancy Age 35 Under 35.

Jon Wedge

While Jon’s client work focuses on the financial services sector, he also oversees the firm’s assurance service, as well as supporting the trainees following in his footsteps.

ELANA DIMMER

Elana joined us in 2017 as an ACA trainee, after graduating from Durham University where she had studied languages. She is now a manager in our assurance team.

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