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Tutorial Course

UK Taxation

Led by Reginald Arthur Chetham-Wade Simulacrum

8 modules 8 modules · ~13 hours Accounting & Business Updated yesterday

Eight tutorials on UK taxation across the principal taxes — income tax, National Insurance, PAYE, corporation tax, VAT, capital gains tax, inheritance tax, and the framework for tax avoidance, evasion, and dispute resolution. Reginald Arthur Chetham-Wade Simulacrum leads — fictional archetype of a 35-year career inside the Inland Revenue (joined 1968; retired 2003 at the HMRC merger) now in private tax consultancy. Stage 3 of the Accounting & Finance (UK) programme.

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UK Tax Architecture …1Income Tax for Indiv…2National Insurance, …3Corporation Tax4Capital Gains Tax5Value Added Tax6Inheritance Tax and …7Tax Avoidance, Evasi…8
  1. Module 1 ○ Open

    UK Tax Architecture · Statutes, Agencies, Frameworks

    Led by Reginald Arthur Chetham-Wade Simulacrum

    The question

    An introduction to the UK tax system at the architectural level. Chetham-Wade Simulacrum covers the principal statutes (ITEPA 2003, ITTOIA 2005, ITA 2007, CTA 2009, CTA 2010, TCGA 1992, IHTA 1984, VATA 1994), the agency (HMRC and its predecessors), the compliance frameworks (self-assessment, PAYE, VAT registration, corporation-tax self-assessment), the interpretive principles (statute primacy, the Ramsay purposive construction, the GAAR backstop), and the appeal route from an HMRC decision through the Tax Chamber tribunals to the Supreme Court.

    Outcome

    The student can identify the principal UK tax statutes and which tax each governs; can articulate the self-assessment, PAYE, and VAT compliance frameworks; can distinguish avoidance from evasion; and can outline the appeal route from an HMRC decision. (UK tax architecture)

    Practice scenarios

    Orienting a New Tax Trainee

    You orient a new tax trainee at a UK mid-market accountancy firm with a portfolio of small companies, individual self-assessment clients, family-trust matters, and occasional owner-managed-business advisory work. The work tests whether you can structure the trainee's learning order, point to the right daily-use resources, identify the careful-of pitfalls, and explain the inspector's-view discipline of reading returns against patterns of risk.

    Your goals

    • Recommend the learning order: (1) the architecture of statutes and agencies (this module); (2) the income tax framework for individuals (Module 2); (3) PAYE and National Insurance for employers (Module 3); (4) corporation tax for the small-company portfolio (Module 4); (5) capital gains tax for the investor and OMB clients (Module 5); (6) VAT (Module 6); (7) inheritance tax and trusts for the family-business clients (Module 7); (8) the avoidance-evasion-disputes framework (Module 8).
    • Identify the daily-use resources: HMRC's online manuals (PIM, EIM, BIM, CTM, CGT, IHTM, VATM); the CCH or Tolley tax handbooks; the firm's internal tax-knowledge database; the *Tax Journal* and *Taxation* magazines for current developments.
    • Identify the careful-of: do not rely on memory for rates and thresholds (always check the current rate); do not advise without identifying the relevant statute (HMRC manuals are useful but not legal authority); do not give clients a false sense of certainty on uncertain points (mark advice as such); always document the analysis (the working file is the firm's protection in negligence claims).
    • Identify the *inspector's view* — the trainee should remember that every return is read, increasingly by automated systems, against patterns of risk; the inspector's pencil hovers over: industry benchmarks not met; ratios outside expected range; cash businesses with no PAYE; partial-exemption VAT calculations; loss claims; close-company loans; pension-contribution patterns; trust returns with property transactions; offshore links.
    • Frame as a 1,200-word orientation memo for the trainee.
  2. Module 2 ○ Open

    Income Tax for Individuals

    Led by Reginald Arthur Chetham-Wade Simulacrum

    The question

    Income tax for individuals — the largest single UK tax by yield. The module covers the income types (employment, self-employment, property, savings, dividends, pensions, foreign), the personal allowance and its taper above £100k, the rate bands for 2024–25, the savings allowance and dividend allowance, the principal reliefs (pension contributions, ISA, EIS, SEIS, VCT, Gift Aid, Marriage Allowance), the high-income child benefit charge, and the self-assessment compliance discipline. The post-April-2025 FIG regime replacing remittance basis is introduced.

    Outcome

    The student can perform a UK personal income tax computation including all income types, allowances, and rate bands; can apply the personal-allowance taper; can calculate tax on dividends and savings income separately; and can identify the principal reliefs available. (Income tax for individuals)

    Practice scenarios

    Self-Assessment for a High-Earning Professional

    You prepare the 2024–25 self-assessment computation for a high-earning UK consulting professional — £140k salary, £30k bonus, £8.5k benefits, £24k buy-to-let income, dividends, savings, EIS investment, charitable giving — including the personal-allowance taper, pension-contribution band extension, mortgage-interest restriction, and EIS relief. The work tests whether you can integrate eight income types and six reliefs into a defensible self-assessment computation.

    Your goals

    • Calculate adjusted net income for personal-allowance taper: salary + bonus + BIK + rental net + dividends + savings, less pension contribution = approximately £170,000 + minor items; gross adjusted net £176k. Personal allowance fully tapered (income above £125,140); PA = nil.
    • Calculate the rental net: £24,000 − £6,500 = £17,500 net; the mortgage interest of £8,000 receives 20% basic-rate relief separately (£1,600).
    • Aggregate non-savings non-dividend income: salary £140,000 + bonus £30,000 + BIK £8,500 + rental £17,500 = £196,000.
    • Apply rate bands extended for pension (£25,000 grossed contribution extends basic-rate band by £25,000): basic-rate band now £12,571 to £75,270; higher-rate £75,271 to £150,140 (£125,140 + £25,000 extension); additional rate above £150,140.
    • Tax on non-savings non-dividend: 20% × (£75,270 − £0) + 40% × (£150,140 − £75,270) + 45% × (£196,000 − £150,140) = £15,054 + £29,948 + £20,637 = £65,639.
    • Tax on dividends: £500 dividend allowance covers £500 at 0%; remaining £3,700; the dividend rate at additional rate is 39.35% × £3,700 = £1,456 (assuming the dividend falls into the top band).
    • Tax on savings: £620 savings interest within personal savings allowance is £0 if higher-rate (allowance £500) or additional-rate (allowance £0); for additional-rate, all £620 taxed at 45% = £279.
    • Apply mortgage-interest basic-rate relief: −£1,600.
    • Apply EIS relief: 30% × £30,000 = £9,000 deduction from tax liability.
    • Apply Gift Aid higher-rate relief: gross donation £3,125 (£2,500/0.8); higher-rate relief = 20% × £3,125 = £625.
    • Final liability: £65,639 + £1,456 + £279 − £1,600 − £9,000 − £625 = approximately £56,149. Less PAYE deducted £18,000 = £38,149 balancing payment plus next year's payments on account.
    • Frame as a 1,500-word self-assessment computation memo for the client.
  3. Module 3 ○ Open

    National Insurance, PAYE, and Employer Compliance

    Led by Reginald Arthur Chetham-Wade Simulacrum

    The question

    National Insurance, PAYE, and the employer-compliance framework — the second-largest UK tax and the largest area of HMRC's compliance activity by case volume. The module covers the National Insurance classes and 2024–25 rates, PAYE operation and Real-Time Information, P11D reporting of benefits in kind, the Construction Industry Scheme, and the off-payroll-working (IR35) regime as substantially reformed in 2017 and 2021. The HMRC employer-compliance review process and typical findings close the module.

    Outcome

    The student can identify the National Insurance class applicable to a worker; can calculate employee and employer NI on a typical salary; can identify common PAYE / P11D / RTI compliance failures; and can articulate the IR35 framework. (NI, PAYE, employer compliance)

    Practice scenarios

    Employer-Compliance Review for a 50-Person Tech Company

    You handle a 4-year HMRC employer-compliance review of a 50-person UK tech consultancy with 12 contractors paid through personal-service companies, varied benefits in kind, and no IR35 Status Determination Statements on file. The work tests whether you can quantify the IR35 exposure, diagnose the benefits and Employment Allowance compliance, recommend the immediate response and longer-term remediation, and resist the CFO's contention that *substitution clauses mean outside IR35*.

    Your goals

    • Diagnose the IR35 risk: the 12 contractors are on day rates with the company; the substitution clause is one factor but not determinative under the *Ready Mixed Concrete* / *Hall v Lorimer* multi-factor test (control, mutuality of obligation, integration, financial risk, equipment); without an SDS on file, the company has not complied with the off-payroll-working obligations introduced from 6 April 2021 for medium and large private-sector engagers; HMRC will likely assess the company for unpaid tax and NI on each engagement classified as inside IR35.
    • Quantify the IR35 exposure: 12 contractors × 4 years × likely 30–60% conversion rate to inside-IR35 = 14–29 engagement-years at risk; estimated tax and NI per engagement-year £25k–£40k; total exposure £350k–£1.2m before penalties.
    • Diagnose the benefits compliance: company cars, private medical, gym membership are all P11D-reportable; the £450/head offsite is likely covered by the *trivial benefits* exemption only if under £50/head for each occasion (so the offsite is fully taxable as a benefit). Check that P11Ds have been filed and Class 1A paid.
    • Diagnose the Employment Allowance: eligible (under 50 employees; not connected with another employer claiming); but check that the calculation reflects the correct year's £5,000 maximum.
    • Recommend the immediate response: cooperate with HMRC; provide all requested information; conduct an internal IR35 review for the 12 contractors using HMRC's CEST tool plus independent legal review; prepare for likely disclosure.
    • Recommend the longer-term remediation: implement SDS process for all contractor engagements; consider moving high-risk contractors to PAYE going forward; review benefits reporting; consider voluntary disclosure under the *Contractual Disclosure Facility* if material understatement found.
    • Frame as a 1,500-word advice memo for the CFO.
  4. Module 4 ○ Open

    Corporation Tax

    Led by Reginald Arthur Chetham-Wade Simulacrum

    The question

    Corporation tax — applied to UK-resident companies on worldwide profits. The module covers the rate structure (small-profits 19%, main 25%, marginal relief between £50k and £250k), the trading-profit computation including the disallowable-expense add-backs and capital-allowances deductions, Full Expensing on plant and machinery, R&D relief under the post-2024 merged scheme, the Patent Box, loss relief and group relief, the Substantial Shareholding Exemption on share disposals, and the Pillar Two minimum-tax regime effective from 2024.

    Outcome

    The student can perform a corporation tax computation including capital allowances, loan-relationships adjustments, and group relief; can identify when the small-profits rate, main rate, or marginal relief applies; and can articulate the principal corporation-tax reliefs (R&D, Patent Box, SSE, group relief). (Corporation tax)

    Practice scenarios

    Corporation Tax Computation for a Mid-Sized Group

    You compute corporation tax for Halberd UK Limited at year-end — £8.4m accounting profit, £2.1m of qualifying capex, £450k of R&D, intercompany management charge, group relief surrendered in — applying Full Expensing, the merged-scheme R&D credit, group relief, and the 25% main rate with QIPs. The work tests whether you can integrate every major corporation-tax mechanism into one defensible computation.

    Your goals

    • Adjust accounting profit: + depreciation £1.2m (add back; replaced by capital allowances); + £40k client entertainment (disallowed); + £35k acquisition advisory legal fees (capital, disallowed; depending on treatment) — note: post-2002 intangible regime may have different treatment; staff entertainment £140k is allowable below £150/head/event with conditions — assume allowable; commercial litigation £50k allowable.
    • Apply full expensing on £2.1m capex: 100% first-year deduction for main-pool plant under Full Expensing rules.
    • Apply R&D relief: post-1-April-2024 merged scheme — 20% expenditure credit on £450k qualifying = £90k below-the-line credit (taxable but reduces tax payable); illustrate as either above-the-line or as effective rate effect.
    • Loan-relationships credit: £75k taxable income (CTA 2009 Part 5).
    • Group relief: £350k claim to reduce taxable profit.
    • Calculate taxable trading profit: accounting £8.4m + £1.2m depreciation + £40k entertainment + £35k acquisition fees = £9.675m; less full expensing £2.1m = £7.575m; less R&D enhancement (under merged scheme, the credit is calculated separately); less group relief £350k = £7.225m; plus loan-relationships £75k = £7.3m taxable profit.
    • Apply rate: full main rate 25% on £7.3m × 25% = £1.825m; less R&D credit £90k = £1.735m corporation tax payable.
    • QIPs: payable in 4 instalments based on this estimate (months 7, 10, 13, 16 of the accounting period for *large* companies; *very large* >£20m profit pays earlier).
    • Frame as a 1,500-word corporation tax memo for the head of tax.
  5. Module 5 ○ Open

    Capital Gains Tax

    Led by Reginald Arthur Chetham-Wade Simulacrum

    The question

    Capital gains tax — applied to UK individuals, trusts, and personal representatives on disposals of chargeable assets. The module covers the gain computation (proceeds less acquisition cost less enhancement less incidental costs), the annual exempt amount (£3,000 for 2024–25), the rates pre and post 30 October 2024, the principal reliefs (Business Asset Disposal Relief, Investors' Relief, Private Residence Relief, Holdover Relief, Rollover Relief, EIS/SEIS deferral), the share-matching rules, and the 60-day reporting requirement for residential property disposals.

    Outcome

    The student can perform a CGT computation for a typical individual including the principal reliefs; can apply the share-matching rules to a portfolio disposal; can identify when BADR or Investors' Relief is available; and can articulate the 60-day reporting requirement for residential property. (Capital gains tax)

    Practice scenarios

    Owner-Manager Selling the Family Business

    You advise a 60-year-old founder on the tax planning for a £4.2m sale of his trading-company shares, including BADR application, EIS deferral of the post-BADR gain, and the deferred-consideration treatment under Marren v Ingles. The work tests whether you can construct an integrated plan minimising current CGT while preserving optionality, and defend the EIS deferral strategy to the client's solicitor.

    Your goals

    • Calculate the gain: proceeds £4.2m (cash + earn-out at present value); acquisition cost £80k; gain approximately £4.12m. (For deferred consideration, the *Marren v Ingles* principle treats the right to future payments as a chose in action acquired for its market value; later receipts are taxed as separate gains/losses. Alternative: under earn-out election, treat as cash-equivalent at completion.)
    • Apply BADR: lifetime £1m allowance, less £100k used = £900k remaining; 10% on £900k = £90,000 CGT (under BADR; pre-30 October 2024 disposal date, so 10% rate applies — note disposal is 30 September, so under the old regime).
    • Apply main rate on excess: £4.12m gain − £900k BADR = £3.22m at 20% (pre-30 October 2024 rate for higher-rate individual) = £644,000 CGT. (If disposal had been 30 October or later: 24% rate on excess = £772,800.)
    • Total CGT: £90,000 (BADR) + £644,000 (main) = £734,000.
    • Less annual exempt amount £3,000: £731,000.
    • Identify EIS deferral opportunity: £731,000 of gain at 24% (notional residual rate) — reinvest £731,000 in EIS-qualifying companies within the 3-year window; defers gain until disposal of EIS shares; subject to investment limits (£1m EIS per year, £2m for knowledge-intensive); not currently using full capacity.
    • Recommend: defer remaining £731,000 of post-BADR gain via EIS investments over the next 36 months (the *deferral window* is 1 year before to 3 years after disposal); reduces immediate CGT to £90,000 (BADR portion only); the EIS shares retain risk and lock-up.
    • Address the deferred-consideration treatment: clarify whether to elect the earn-out treatment (deferred-consideration matched to disposal date) or apply *Marren v Ingles* (right valued at completion, future receipts separate); the BADR application requires the disposal at completion with appropriate election.
    • Frame as a 2,000-word capital gains tax planning memo for the client.
  6. Module 6 ○ Open

    Value Added Tax

    Led by Reginald Arthur Chetham-Wade Simulacrum

    The question

    Value Added Tax — the second-largest UK tax by yield. The module covers the rate categories (standard 20%, reduced 5%, zero, exempt), the registration threshold (£90k from April 2024), the VAT return cycle, the place-of-supply rules for cross-border services, the post-Brexit framework including postponed VAT accounting and the Northern Ireland Protocol, partial exemption for businesses with both taxable and exempt supplies, the Capital Goods Scheme, and the special schemes (Flat Rate, Cash Accounting, Tour Operators Margin Scheme). MTD for VAT compliance closes the module.

    Outcome

    The student can determine whether a supply is standard-rated, reduced, zero-rated, or exempt; can identify the registration threshold; can perform a basic partial-exemption calculation; and can articulate the post-Brexit cross-border-supply framework. (Value Added Tax)

    Practice scenarios

    VAT Compliance for a Multi-Activity Business

    You work the VAT compliance position for a UK training-and-publishing business with three activities (corporate training, government-funded apprentice training, books and digital materials) plus cross-border supplies to and from US and Germany. The work tests whether you can apply partial-exemption rules with the standard method and de-minimis test, handle the place-of-supply rules post-Brexit, and resolve the reverse-charge mechanism on the German supplier.

    Your goals

    • Determine the VAT treatment of each activity: corporate training is standard-rated supply; government-funded apprentice training is exempt (supplied by an accredited provider); physical books are zero-rated; digital course materials are standard-rated (digital books became zero-rated from May 2020 only for primarily *literary* content; digital training materials remain standard-rated unless they qualify as electronic publications).
    • Calculate output VAT: £420k × 20% = £84k; £95k digital materials × 20% (assume all digital materials, illustrative) = £19k. Total output £103k.
    • Identify partial-exemption application: business has both taxable (training, books, digital materials) and exempt (apprentice) supplies; input VAT must be apportioned for inputs not directly attributable.
    • Apply standard partial-exemption method: directly attributable to taxable supplies — recover; directly attributable to exempt — not recover; mixed inputs (overheads) apportioned by turnover ratio. Turnover taxable: £420k + £95k = £515k. Turnover exempt: £180k. Total: £695k. Recovery rate on mixed inputs: 515/695 = 74%.
    • Estimate the input-VAT split: assume £90k directly attributable to taxable, £20k directly attributable to exempt, £30k mixed. Recovery: £90k (full) + £30k × 74% (£22.2k) = £112.2k recoverable.
    • Apply de minimis test: exempt-attributable input £20k + £30k × 26% = £20k + £7.8k = £27.8k; this exceeds the de-minimis threshold (£625/month × 12 = £7,500); so partial exemption applies as calculated.
    • Address the US consultancy: place of supply is the recipient's location (US, B2B general rule); outside scope of UK VAT; charge no UK VAT on the £45k.
    • Address the German supplier: place of supply for B2B services from non-UK supplier is the recipient (UK); UK reverse charge applies — the client accounts for £28k × 20% = £5.6k as output VAT and recovers as input (subject to partial-exemption attribution).
    • Calculate net VAT: output £103k + reverse charge £5.6k = £108.6k; less recoverable input £112.2k; net repayment position £3.6k.
    • Frame as a 2,000-word VAT advisory memo including the recommended approach for the partial-exemption documentation file.
  7. Module 7 ○ Open

    Inheritance Tax and Trusts

    Led by Reginald Arthur Chetham-Wade Simulacrum

    The question

    Inheritance tax and trusts — the UK succession-tax regime. The module covers the transfer-of-value concept, the distinction between potentially-exempt transfers and chargeable lifetime transfers, the nil-rate band (£325,000) and residence nil-rate band (£175,000) and their transferable form between spouses, the 7-year rule and taper relief, the principal reliefs (Business Property Relief, Agricultural Property Relief — both substantially restricted from April 2026), the relevant property regime for discretionary trusts, and the post-April-2027 reform bringing pensions into the IHT estate.

    Outcome

    The student can perform a death-estate IHT computation including NRB, RNRB, TNRB, BPR, and APR; can articulate the relevant property regime for discretionary trusts; can identify the principal lifetime exemptions; and can advise on the impact of the post-2026 reforms to trust and pension treatment. (Inheritance tax and trusts)

    Practice scenarios

    Estate Planning for a Family-Business Owner

    You produce an estate-planning analysis for a UK couple with a £6.7m combined estate including £4.2m of trading-company shares qualifying for BPR, ahead of the April 2026 reform that caps BPR at £1m. The work tests whether you can compute the IHT position pre and post reform, evaluate lifetime-gifting and trust-based options, and structure a recommendation for a reluctant founder unwilling to surrender control.

    Your goals

    • Calculate the current IHT position assuming both deaths occur post the spouse-exemption pass-through but before April 2026 (when BPR rules change): combined estate £6.7m. NRB £325k + TNRB £325k = £650k; RNRB £175k + TRNRB £175k = £350k (subject to taper above £2m estate — RNRB tapers to nil at estate value above £2.7m or so, so both RNRB amounts are entirely tapered away on a £6.7m estate). BPR on the trading shares (current rules): 100% × £4.2m = £4.2m exempt. Net taxable estate: £6.7m − £4.2m BPR − £650k NRB = £1.85m at 40% = £740,000 IHT.
    • Calculate the position post-April 2026: BPR cap of £1m at 100%, 50% on excess. BPR available: £1m + (£4.2m − £1m) × 50% = £1m + £1.6m = £2.6m. Net taxable estate increases: £6.7m − £2.6m − £650k = £3.45m at 40% = £1.38m IHT. The reform increases IHT by approximately £640k.
    • Identify planning options: (a) lifetime gifting of the trading shares to children now (PET; survives 7 years and the gift becomes exempt; transitional question on whether the gift is made before or after April 2026 with respect to BPR availability); (b) discretionary trust into which trading shares are transferred (CLT subject to 20% on excess over NRB; but BPR available at lifetime transfer); (c) deferred-action approach — wait until the rules are clearer post-2025–26 transitional consultations; (d) charitable bequest — leaving 10%+ of net estate to charity reduces rate to 36% (saves up to 4% × net taxable estate).
    • Recommend (illustrative): assess the family-business succession plan first — are the children ready to receive the trading-company shares (taking on the business, the BPR risk if the company shifts to non-trading status, etc.)? If yes, lifetime PET of the trading shares to one or more children (with appropriate trust structures if appropriate); execute pre-April-2026 to lock in 100% BPR; the parents survive 7 years for the gift to fall out of estate. Other planning: review the will to ensure RNRB-friendly structuring (if the residence is to pass to descendants; though the £2m taper makes RNRB largely unusable here); consider charitable bequest to bring rate to 36%.
    • Frame as a 2,500-word estate planning memo for the clients covering current position, post-2026 position, principal options, and the recommended approach.
  8. Module 8 ○ Open

    Tax Avoidance, Evasion, and Disputes

    Led by Reginald Arthur Chetham-Wade Simulacrum

    The question

    Tax avoidance, evasion, and disputes — the framework within which all UK tax practice operates. The module covers the avoidance-evasion-planning spectrum, the Ramsay purposive-construction line of cases, the General Anti-Abuse Rule and the GAAR Advisory Panel, the DOTAS and POTAS disclosure regimes, the Loan Charge and disguised-remuneration anti-avoidance, the corporate offence under the Criminal Finances Act 2017, the Professional Conduct in Relation to Taxation (PCRT) standards binding UK tax practitioners, and the inquiry-and-appeal route. The closing scenario refuses a contractor-loan tax-avoidance scheme.

    Outcome

    The student can articulate the avoidance-evasion-planning spectrum and the relevant statutory and professional responses; can identify when the GAAR, Ramsay, or PCRT standards apply; can advise a client on the inquiry-and-appeal route; and can articulate the practitioner's professional and ethical responsibilities. (Tax disputes and professional conduct)

    Practice scenarios

    The Tax-Avoidance Scheme Proposal

    You decline to support a contractor-loan tax-avoidance scheme proposed to your sports-professional client by another adviser, while offering legitimate alternatives. The work tests whether you can apply the disguised-remuneration legislation, GAAR, and DOTAS analysis to identify the exposure; whether you can hold to the PCRT professional standard against client pressure; and whether you can articulate the risk of the Loan Charge convincingly to a client persuaded by *the other adviser has 200 clients in this scheme*.

    Your goals

    • Diagnose the scheme: this is a *disguised remuneration* arrangement of the type targeted by the *Disguised Remuneration* legislation in Finance Act 2011 onwards; the *Loan Charge* applies retrospectively to outstanding loans as of 5 April 2019; current arrangements continue to be challenged under Part 7A ITEPA 2003 and similar provisions.
    • Identify the statutory exposure: the loans will likely be treated as employment income at the time of receipt; the ITEPA Part 7A targeted-anti-avoidance rules apply; the *settlements legislation* and *transfer-of-assets-abroad* rules may also engage; the client faces both back-tax assessments and penalties.
    • Identify the GAAR exposure: the scheme is an artificial structure designed primarily for tax saving; the GAAR may apply (though specific anti-avoidance is more likely the route); the GAAR Advisory Panel has previously found contractor-loan schemes within GAAR scope.
    • Identify the DOTAS exposure: contractor-loan schemes have been subject to extensive DOTAS scrutiny; specific schemes have been *named* by HMRC; participation may be reportable under DOTAS by the user even if the promoter has not registered.
    • Identify the practitioner's PCRT obligation: the *standards for tax planning* prohibit advising on schemes that are contrary to the *clear intention of Parliament*; this scheme is exactly that; you cannot advise on the proposal.
    • Recommend to the client: do not enter the scheme; the *promoter's promised effective rate* will not be achieved; the client will face back-tax assessments, interest, and penalties (potentially 30%–100%); the *Loan Charge* and similar measures may apply; HMRC has been aggressive in pursuing these schemes; the proposal is professionally and personally damaging.
    • Address the legitimate alternatives: pension contributions to extend the basic-rate band; charitable giving; EIS/SEIS investment; appropriate corporate structuring (his own personal-service company subject to IR35 review and dividend extraction); these are legitimate, defensible, and compliant with PCRT.
    • Frame as a 1,500-word advice memo declining to support the scheme and offering the legitimate alternatives.