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  1. Commercial terms. Loans made on commercial terms by an employer whose business includes the making of loans, where a substantial proportion of those loans are made to members of the public at large, and at arm’s length, are excluded from liability to tax. The terms on which the loans are made to the employee must be comparable to the loans to the public.150


  2. Fixed-term loans originally at the official rate. The charge is aimed at loans below the official (market) rate of interest. If the loan is a fixed-interest loan and was not below that rate when it was made the subsequent increase in the official market rate in a later year does not cause the loan to become chargeable.151


  3. Death. An employee’s loan ceases to be outstanding on his death,152 as such, no cash equivalents can arise for later periods.


  4. Other termination of employment. Although the legislation does not in terms address the issue of the ending of employment section 175 (ex 160(1)) applies only for those periods during which while the person is in employment.153


  5. Qualifying loans. Qualifying loans are loans in respect of which the borrower can claim deduction for the interest as a trading expense or as being for eligible for relief under section 353.154 Qualifying loans are not taken into account in calculating the de minimis limit of £5,000.155


  6. Bridging loans. Section 173(3) carefully makes a cross reference to the exemption in sections 288 and 289 for certain bridging loans connected with employment moves; those exemptions mean that section 175 is excluded also. No liability can arise under section 188 because loan must be discharged before end of period.

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