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 (‘the review’), 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 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 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 ceu.enquiries@hmtreasury.gov.uk 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 HMRC. Contact details for the reviewer have been published by HM Treasury.
HMRC has now finished sending letters and a ‘question and answer’ document to customers to:
- give them a named HMRC contact
- set out whether HMRC think the disguised remuneration arrangements they used will be considered by the review or not, and explain what HMRC’s operational approach to customers will be in their case during the review
Copies of the letter text sent to customers can be found on this page:
- Letter 1: mixed disguised remuneration arrangements - considered by the review
- Letter 2: disguised remuneration arrangements – considered by the review
- Letter 3: settled disguised remuneration arrangements – considered by the review
- Letter 4: disguised remuneration arrangements – not considered by the review
For customers who have received a letter, if you think that you’ve 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 won’t 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 will then write to customers again to update them on next steps.
For other general disguised remuneration enquiries, customers can continue to contact HMRC on 0300 322 9420.