EIM47105 | Paras 2(6), 19 to 22: loan charge relevant step: qualifying loans introduction

Schedule 11 F(No 2)A 2017

Where a loan charge relevant step is taken, the date on which the step is treated as taken will be 5 April 2019. There are some circumstances when that date can be altered.

If the loan or quasi-loan is what is known as an approved fixed term loan, the date will be the date on which the loan was due to be repaid in full. This date is known as the approved repayment date.

In order to become an approved fixed term loan, the loan has to fulfil certain basic criteria (see EIM47110) and meet either a qualifying payments condition (see EIM47115) or a commercial terms condition (see EIM47120). An application to HMRC needs to be made in respect of such loans.

Where the whole or part of such a loan or quasi-loan is outstanding on the approved repayment date, P is treated as taking a relevant step for the outstanding amount of the loan or quasi-loan on that date.