Skip to main content
Guidance

Disguised remuneration: 2019 independent loan charge review

Information relating to the 2019 independent review of the disguised remuneration loan charge.

Updates to this page

From:
HM Treasury and HM Revenue & Customs
Published:
11 September 2019
Last updated:
26 November 2025
Show all updates

  1. Page updated after publication of government response to the independent loan charge review in Budget 2025.

  2. Page updated to reflect the recent publication by the government of the terms of reference for the new independent review of the Loan Charge.

  3. Page updated to reflect government's announcement that there will be a further independent review of the loan charge.

  4. The loan charge helpline phone number has been changed from 03000 599110 to 0300 322 9494.

  5. The information about making a late election to spread your outstanding loan balance has been updated.

  6. Page updated with links to 'Independent Loan Charge review: HMRC report on implementation' and HMRC's 'Interest rate review'.

  7. Added information on applying for a late election to the disguised remuneration guidance.

  8. We have updated the guidance with information on what customers affected by the loan charge should do now the 30 September 2020 deadline has passed.

  9. We have updated the guidance and included information about the voluntary restitution refunds.

  10. Published 'Independent loan charge review: HMRC’s review of future policy on interest rates within the tax system'.

  11. The page was updated on 27 February with new information about what employers should do following the outcome of the Review.

  12. Guidance following the outcome of the independent loan charge review has been updated to include information about accelerated payment notices, Inheritance Tax and disclosure. It includes more information about filing Self Assessment tax returns, late payment interest and payments on accounts.

  13. Updated with review document, government response document, and updated guidance.

  14. Updated with 'Letter from the FST to Sir Amyas Morse'.

  15. Updated text under 'contacting the review and providing supporting evidence'

  16. The page has been updated to add the contact details for the review, explain that people can send it evidence, clarify who has published the supporting documents on the page, and shorten the description of the review. Also updated document title for 'Disguised remuneration: Loan charge review'

  17. First published.

Documents

New independent review of the loan charge (2025)

HTML

Disguised remuneration: guidance following the outcome of the 2019 independent loan charge review

HTML

Independent Loan Charge Review (2019): terms of reference

PDF, 158 KB, 2 pages

Letter from the FST to Sir Amyas Morse

PDF, 132 KB, 1 page

Independent Loan Charge Review (2019): report

PDF, 1.13 MB, 83 pages

The Government’s Response to the Independent Loan Charge Review (2019)

PDF, 303 KB, 19 pages

Independent loan charge review (2019): HMRC’s review of future policy on interest rates within the tax system

HTML

Independent Loan Charge review (2019): HMRC report on implementation

https://www.gov.uk/government/publications/independent-loan-charge-review-hmrc-report-on-implementation

Interest rate review

https://www.gov.uk/government/publications/interest-rate-review

Details

The government has published its response to the independent loan charge review in Budget 2025. 

HMRC is reviewing what this means for customers and you can find the latest update here.

2019 Independent Loan Charge Review

In September 2019, the Chancellor commissioned Sir Amyas Morse to lead an independent review into the disguised remuneration loan charge. Sir Amyas was asked to consider whether the policy is an appropriate response to the tax avoidance behaviour in question, and whether the changes the government has announced to support individuals to meet their tax liabilities have addressed any legitimate concerns raised.

The review has concluded and the government has published its response. HMRC has published guidance setting out what this means for those affected.

In December 2020 HMRC published their report on actions they have taken to implement all of the nineteen accepted recommendations of the Independent Loan Charge Review. This report fulfils recommendation 14 of the Independent Loan Charge Review which specifically asked that HMRC report to Parliament on its implementation of the Loan Charge before the end of 2020.

Sign up for emails or print this page

Related content