Legislation – Finance Act 2026
Changes to legislation:
Finance Act 2026, Section 27 is up to date with all changes known to be in force on or before 17 April 2026. There are changes that may be brought into force at a future date. Changes that have been made appear in the content and are referenced with annotations.
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- Pt. 15 excluded by S.I. 2026/331 reg. 19
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Part 1Income tax, capital gains tax and corporate taxes
Other employment income
27Loan charge settlement scheme: supplementary
(1)
The scheme may make provision—
(a)
about the process of making settlement offers and entering into settlement agreements;
(b)
for settlement offers to be conditional upon the persons to whom they are made doing specified things;
(c)
about the terms which may, must or may not be included in settlement agreements;
(d)
supplementing—
(i)
provision made under section 25(6) about the calculation of settlement amounts, and
(ii)
the definitions in section 25(7) of “loan charge amount” and “loan charge gross liability”;
(e)
adapting provision made under section 25(6), in cases where a settlement offer is made to a person who is not an individual, about the calculation of settlement amounts (including provision for the calculation to be different to what is required by section 25(6));
(f)
for the use of estimates in relation to any amount;
(g)
about liabilities which are incidental to, or otherwise connected with, loan charge amounts;
(h)
for amounts paid by a person towards the person’s loan charge gross liability to be credited against a liability of the person to pay a settlement amount (but to no greater extent than discharging that liability);
(i)
for anything else the Treasury consider appropriate for the purpose of the scheme.
(2)
The things specified under subsection (1)(b) may include, for example, a person to whom a settlement offer is made entering into a contract settlement in relation to amounts specified in the settlement offer which—
(a)
are not loan charge amounts,
(b)
are payable, or become payable in the future, to the Commissioners by the person under or by virtue of any enactment, and
(c)
have not yet been paid.
(3)
The provision which may be made under subsection (1)(d)(ii) includes provision setting out the descriptions of amounts which arise in connection with a Schedule 11 or 12 to F(No. 2)A 2017 loan or quasi-loan.
(4)
The provision which may be made under subsection (1)(g) includes provision—
(a)
treating penalties, or other amounts which are not loan charge amounts but are connected with them, as never having arisen or ceasing to be payable, and
(b)
crediting amounts paid towards such liabilities against other liabilities to pay a settlement or other amount to the Commissioners or for the Commissioners to repay those paid amounts.
(5)
The scheme may make—
(a)
different provision for different purposes or cases;
(b)
provision generally or for specified cases;
(c)
provision subject to exceptions;
(d)
incidental, supplementary, consequential or transitional provision.
(6)
Regulations providing for the scheme are to be made by statutory instrument and are subject to annulment in pursuance of a resolution of the House of Commons.
(7)
A settlement agreement is a contract settlement for the purposes of sections 25 and 25A of CRCA 2005.
(8)
Expressions used in this section and section 25 or 26 have the same meaning in this section as they have in section 25 or 26.