Issue briefing: Loan charge letters
This briefing explains how HMRC is liaising with customers during the independent review of the loan charge.
Documents
Details
Introduction
This briefing explains the operational activity that HM Revenue and Customs (HMRC) will undertake during the new independent review of the Loan Charge (鈥榯he review鈥�), 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聽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聽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聽[email protected]聽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聽HMRC. Contact details for the reviewer聽have been published by HM Treasury.
HMRC聽has now finished sending letters and a 鈥榪uestion and answer鈥� document to customers to:
- give them a named聽HMRC聽contact
- set out whether聽HMRC聽think the disguised remuneration arrangements they used will be considered by the review or not, and explain what聽HMRC鈥檚 operational approach to customers will be in their case during the review
Copies of the letter text 聽sent to customers can be found on this page:
- Letter 1:聽mixed disguised remuneration arrangements聽 - considered by the review
- Letter 2: disguised remuneration arrangements 鈥� considered by the review
- Letter 3: settled disguised remuneration arrangements 鈥� considered by the review
- Letter 4: disguised remuneration arrangements 鈥� not considered by the review
For customers who have received a letter, if you think that you鈥檝e received the wrong letter, or should not have received a letter, please tell the named contact included in your letter.
For customers who have not received a letter but think they should have received one, please contact us on 0300 322 9420.
HMRC聽won鈥檛 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聽will then write to customers again to update them on next steps.
For other general聽disguised remuneration聽enquiries, customers can continue to contact聽HMRC聽on 0300 322 9420.