Guidance

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

Updated 4 March 2021

In September 2019, the Chancellor commissioned Sir Amyas Morse to lead an independent review into the disguised remuneration loan charge. One of the recommendations contained within Sir Amyas’s report, which the government accepted, related to the manner in which interest is charged on payment arrangements and how policy on interest is applied in the tax system.

The work on this has been delayed due to coronavirus (COVID-19), and the Financial Secretary to the Treasury has agreed that the deadline for the report to be presented to Parliament, which was originally 31 July, should be extended to 30 November 2020.

HMRC is announcing that as part of this review into the rationale behind the policy, it will consider:

  • the underlying principles for HMRC charging and paying interest
  • the difference between interest rates charged and paid
  • commercial interest rates applied in the financial products market
  • interest rates used by comparable tax authorities internationally
  • HMRC communications with taxpayers who are liable to interest dating back a number of years
  • any interactions with other government reviews and initiatives

The findings will be published in late autumn 2020.