EIM47015 | Para 1(2) and (6): loan charge relevant step: timing of relevant step
From HM Revenue & Customs · Employment Income Manual
Schedule 11 F(No 2)A 2017
Where an amount of a loan or quasi-loan is outstanding, the person (“P”) who made the loan or quasi-loan is treated as taking a relevant step immediately before the end of 5 April 2019.
There are 2 exceptions to this: