It was announced last month that following the consultation launched during summer 2013, there will be no immediate changes to the structure or operation of the tax charge on loans to participators by close companies.

The Institute’s Northern Ireland Tax Committee had called for no changes to the regime in its response to that consultation, arguing that the consultation document lacked any meaningful data to support the apparent concern expressed regarding abuse. In addition, HMRC have sufficient powers at their disposal to deal with any perceived abusive schemes or practices that may arise in the future. The consultation had originally proposed several options for changing the regime including introducing a new permanent tax charge on such loans.