Policy paper

Implementation of changes to the loan charge

This measure explains changes to the loan charge following recommendations from the independent review published on 20 December 2019.


Draft legislation

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Explanatory note


On 20 January, the Government published draft legislation to implement changes to the loan charge in response to recommendations in the Independent Loan Charge Review.

On 27 February, the Government published draft legislation to refund certain voluntary payments (‘voluntary restitution’) made on or after 16 March 2016 as part of a settlement with HMRC, in relation to loans made in unprotected years. The legislation requires HMRC to set up a scheme to administer refunds. HMRC has published the draft scheme document which sets out the eligibility criteria for claiming a refund, the claims process and how refunds will be calculated. This is a technical document and is not intended to be guidance. Detailed guidance for customers on the claims process and how refunds will be calculated will be published before Royal Assent. Those who want to claim a refund should await this further guidance before taking any action.

Refunds can only be issued after the Finance Bill has received Royal Assent.

The draft legislation and scheme document have been published for technical consultation before the Finance Bill is laid before Parliament. The consultation is intended to ensure that the legislation and scheme work as intended. Any comments on the draft legislation, including that published on 20 January, or the draft scheme, should be sent by email to: loanchargeconsultationresponses@hmrc.gov.uk.

Legislation reflecting any changes following consultation will be published after the Budget as part of Finance Bill 2020.

Published 20 January 2020
Last updated 27 February 2020 + show all updates
  1. A tax information and impact note, further draft legislation, explanatory note and draft scheme have been added regarding refunding voluntary restitution.

  2. First published.