Guidance

Disguised remuneration: transfer of liability - technical note

This technical document sets out how HM Revenue and Customs will collect outstanding tax liabilities from the appropriate person where it can't reasonably collect the liability from the employer.

Documents

Annex A

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Annex B

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Details

The technical note describes how HM Revenue and Customs (HMRC) will transfer the tax liability from the employer to the employee, when HMRC can’t reasonably collect the liability from the employer. It details the process for the transfer in three separate scenarios; where the employer no longer exists, is offshore, or can’t pay the liability. The note also contains the primary and secondary legislation that will be introduced to allow HMRC to transfer the liability from employer to employee.

Published 1 December 2017
Last updated 8 December 2017 + show all updates
  1. The email contact details for contractor loan schemes and all other disguised remuneration schemes has been updated.
  2. First published.