The 2019 Loan Charge was introduced by the Finance (No. 2) Act 2017. It is a tax charge on “employment-related taxable loans made by third parties on or after 6 April 1999 brought within Part 7A ITEPA 2003 if they remain outstanding on 5 April 2019” (ref HMRC guidance).
Part 7A was introduced with the Finance Act of 2011 (December 2010).
Therefore, to apply this to loans going back to 1999 is, by even the most layman terms, retrospective taxation. Furthermore, the loan charge legislation itself was clearly not in existence until 2017 (date of Royal Assent)
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