HMRC have issued a briefing on operational activity during the recently announced loan charge review. The loan charge review is underway and expected to conclude by summer 2025.
The Terms of Reference were published last week and outlined what will be covered in the review.
What to expect if you are currently affected
HMRC intend to write to taxpayers who have ongoing settlements relating to their use of Disguised Remuneration schemes. They are expected to have contacted all taxpayers by mid-March.
As of 10 February 2025, HMRC have started sending letters out to indiviuals affected by the review. The letters contain:
- A named contact at HMRC.
- Confirmation of whether the scheme used by the taxpayer falls under the scope of the new review. If taxpayers disagree with HMRC’s assessment of the scheme used, they can liaise with their named contact.
- What taxpayers should do next.
HMRC will also write to taxpayers who have already Settled their Outstanding Liabilities but have not yet paid in full.
HMRC’s operational approach will be directed at:
- Taxpayers who have used schemes that HMRC believe to be within the scope of the review.
- Taxpayers who have used schemes that HMRC believe are not within the scope of the review.
- Taxpayers who have used multiple schemes, some of which will be within the scope of the review.
Schemes falling within the scope of the review
HMRC have advised that whilst the review is being undertaken, they will not contact taxpayers falling within this category unless there are statutory deadlines or litigation deadlines that need to be met or the taxpayer wishes to progress with a settlement.
Schemes falling outside the scope of the review
HMRC will continue to liaise with taxpayers who have used schemes not under consideration by the review.
Multiple use of schemes
HMRC will continue to correspond regarding the settlement of outstanding tax liabilities for the schemes that do not fall within the scope of the review. They will not contact taxpayers about the schemes being considered in the review unless there is a requirement to do so for statutory deadlines or litigation deadlines.
If a taxpayer in this situation wishes to settle all schemes at once, a pause on settlement can be requested.
Daily Interest will continue to be applied while the loan charge is being reviewed.
HMRC have advised that taxpayers may want to make an upfront payment to stop interest accruing and that they will be refunded along with repayment interest if there is no charge.
Additional support
HMRC have advised they will continue to signpost vulnerable clients and provide additional support where needed.
Submitting evidence
If you wish to submit evidence for the loan charge review, send your submission to
Useful guides on this topic
Loan charge and disguised remuneration
When do the disguised remuneration rules apply? How do they apply? When does the loan charge apply? What options for settlement are available?
Disguised remuneration loan charge
What is disguised remuneration? What is the loan charge? When does the loan charge apply? Will the loan charge affect me?
Disguised remuneration 2020 settlement opportunity
What is HMRC's position on disguised remuneration loans where settlement was not reached by 30 September 2020? Can a settlement still be reached?
FAQs for disguised remuneration settlements
Can I just repay my loans? What if I have paid the loan charge, can I still settle? How much will it cost to settle? And many other FAQs.
