Policy paper

HMRC operational activity during the new independent review of the Loan Charge

Updated 4 June 2025

Introduction

This briefing explains the operational activity that HM Revenue and Customs (HMRC) will undertake during the new independent review of the Loan Charge (바카라 사이트˜the review바카라 사이트™), for customers who have used disguised remuneration (DR) tax avoidance arrangements.

New independent review of the Loan Charge

The government announced a new independent review of the Loan Charge at Autumn Budget 2024.

The terms of reference for the review has been published by the government. They explain what the review will consider.

The review commenced on 23 January 2025 and is being led by the reviewer and his team, independent of government and HMRC.

Questions about the scope of the review or the terms of reference should be directed to HM Treasury. HM Treasury can be contacted by email or by phone on 020 7270 5000.

Decisions about the operation of the review are a matter for the reviewer and cannot be answered by HMRC. Contact details for the reviewer have been published by HM Treasury.

HMRC바카라 사이트¯has now finished sending letters and a 바카라 사이트˜question and answer바카라 사이트™ document to customers to:

• give them a named HMRC contact
• set out whether HMRC think the disguised remuneration arrangements they used will be considered by the review or not, and explain what HMRC바카라 사이트™s operational approach to customers will be in their case during the review

You can view copies of the letter text sent to customers.

If you are a customer who has received a letter and you think that you바카라 사이트™ve received the wrong letter, or should not have received a letter, please tell the named contact included in your letter.

If you are a customer who has not received a letter but you think should have received one, please contact us on 0300 322 9420.

Important

HMRC won바카라 사이트™t be able to tell customers exactly how they may be affected until both:

• the review is complete, and the findings are published
• the government issues its response to any review recommendations

HMRC will then write to customers again to update them on next steps.

For other general DR enquiries, customers can continue to contact HMRC on 0300 322 9420.

HMRC바카라 사이트™s operational approach

1. Customers who have used DR arrangements that HMRC believe will be considered by the review

After the initial letter, during the review HMRC will not contact customers that our information suggests have only used DR arrangements that will be considered by the review, unless:

• there are important matters such as statutory deadlines or litigation deadlines that we need to meet
• customers tell us that they want to progress their case

Customers with outstanding amounts relating to their use of DR arrangements, who have not settled with HMRC:

• may want to consider making an upfront payment to stop further late payment interest being charged on that amount
• can still settle with HMRC if they want to 바카라 사이트“ HMRC will finalise a settlement with anyone who wants to do so during the review period

Where customers have finalised their tax position for the Loan Charge with HMRC but have not yet paid in full, HMRC will write to these customers to let them know what the review means for their current agreement.

2. Customers who have used DR arrangements that HMRC believe will not be considered by the review

HMRC will continue to engage with customers who are still to fully settle their avoidance liabilities. Customers may want to consider making an upfront payment to stop further late payment interest being charged on that amount, whilst HMRC progress their case.

3. Customers who have used multiple DR arrangements, only some of which HMRC believe will be considered by the review

HMRC will contact customers where our information suggests they have used a mixture of avoidance arrangements, some of which will be considered by the review and some of which will not be.

For DR arrangements that we believe will be considered by the review, after the initial letter, HMRC will not contact customers about these arrangements, unless:

• there are important matters such as statutory deadlines or litigation deadlines that we need to meet
• customers tell us that they want to progress their case

HMRC will write to customers again to update them on next steps once the review is complete and the government has issued its response to any review recommendations.

HMRC will continue to engage with customers to finalise their tax positions for DR arrangements that HMRC believe will not be considered by the review.

Customers who would prefer to wait and finalise their tax positions for all their DR arrangements at the same time, can ask HMRC to pause this work until the review is complete.

Where a pause is requested for arrangements that will not be considered by the review, HMRC will not issue assessments nor close any enquiries to finalise the amounts due for these arrangements, unless there are important matters such as statutory or litigation deadlines we need to meet.

Interest

HMRC is required to charge interest on late payments by law. We charge it on a daily basis, from the date amounts were due until the date they바카라 사이트™re paid. This means that late payment interest will continue to build up on tax owed during the review.

Customers who have entered into an agreement to pay the Loan Charge may still want to continue making agreed payments to stop the amount of interest building up.

If we later find there바카라 사이트™s no additional tax to pay, we will refund upfront payments (provided customers don바카라 사이트™t have other tax debts). We바카라 사이트™ll also pay repayment interest on the amount we refund.

Loan Charge legislation

HMRC won바카라 사이트™t know if the amount of tax that customers need to pay will change until after the review has concluded and the government has responded to its recommendations. The Loan Charge legislation remains in force whilst that process takes place.

Independent advice바카라 사이트¨

Customers with a tax adviser may want to talk to them about the terms of reference for the review and the letter HMRC will send to them about this.

For customers who do not have a tax adviser, free advice is available from organisations such as TaxAid and Citizens Advice.

can give tax advice to people on low incomes. For example, they can help check that a tax bill is right and deal directly with us, if needed.

can help people work out ways to pay the tax they owe.

Customers who need extra support

Dealing with tax, financial hardship, or debt can lead to pressure on people, especially those experiencing vulnerable circumstances. HMRC encourages anyone affected to talk to them.  It has guidance and training in place for all customer advisers or settlement teams on identifying customers who need extra support, and providing reasonable adjustments to meet their needs.

Where appropriate, HMRC will signpost customers to voluntary and community organisations and, where needed, to a dedicated Samaritans helpline for specialist emotional help, where customers can talk through their concerns and worries.

HMRC바카라 사이트¯will be writing to customers who have outstanding amounts relating to their use of DR arrangements by mid-March 2025. If a customer needs to speak to HMRC before then, including those experiencing vulnerable circumstances, they should contact HMRC on 0300 322 9420.

For customers who are having a difficult time and it would help to speak to someone, they can access by calling 111, or use free listening services including , and . Friends and family who are concerned about someone바카라 사이트™s wellbeing could also access these services for advice.