This legislation takes effect from 6th April 2011, but includes anti-forestalling measures, so any loan payments made between 9/12/2010 and 6/4/2011, that are not fully repaid by 6/4/2011, will be treated as employment income and taxed accordingly.
Choice Premier is not impacted by the Disguised Remuneration draft legislation, as we do not use a third party to issue loans. Choice Premier issues foreign currency loans directly to its members, which are repaid one year after issue, including interest as HMRCs official rate of interest (currently 4%), so the is no P11d benefit/tax charge.