Commentary on Sections Schedule 7: Transitionals and Savings Part 3: Employment income: earnings and benefits etc. treated as earnings Paragraph 27
3672.The charge to tax under section 188 may be in respect of a loan made before 2003-04. This paragraph deals with the fact that this Act changes the terminology used to describe the beneficial loan arrangements and the charge to tax on them, so that a loan made before 2003-04 may be an employment-related loan.