17 Loan charge reduced where underlying liability disclosed but unenforceable

17  Loan charge reduced where underlying liability disclosed but unenforceable

(1)     In Schedule 11 to F(No 2)A 2017 (employment income provided through third parties: loans etc outstanding on 5 April 2019) after paragraph 1A (as inserted by section 16) insert—

“1

(1)     This paragraph applies where—

(a)     a person is treated as taking a relevant step within paragraph 1 by reason of making a loan or quasi-loan,

(b)     a reasonable case could have been made that for a qualifying tax year (“the relevant year”) A was chargeable to income tax on an amount that was referable to the loan or quasi-loan,

(c)     at a time when an officer of Revenue and Customs had power to recover (from A or any other person) income tax for the relevant year in respect of that amount, a qualifying tax return or two or more qualifying tax returns of the same type taken together contained a reasonable disclosure of the loan or quasi-loan, and

(d)     as at 6 April 2019 an officer of Revenue and Customs had not taken steps to recover (from A or any other person) income tax for the relevant year in respect of that amount.

(2)     But this paragraph

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