On 10 August 2017, HMRC published Spotlight 39, called “Disguised remuneration: re-describing loans”.
Spotlight 39 refers to arrangements under which taxpayers declare that sums received under loan agreements from a disguised remuneration arrangement are not loans because they hold the money in a fiduciary capacity.
These arrangements are intended to circumvent the new charge that will apply to loans made to employees and the self-employed that are outstanding on 5 April 2019, under rules contained in Finance (No. 2) Bill 2017. HMRC is of the view that it is not possible to reclassify something in this manner and that such arrangements do not work.
Spotlight 39 can be found here.