Policy paper

Loan charge letters

Published 22 May 2025

Letter 1: mixed disguised remuneration arrangements  - considered by the Review

What you need to know about the disguised remuneration loan charge review

I’m writing to you because you have previously been paid through disguised remuneration (DR) tax avoidance arrangements.

On 30 October 2024, the government announced a new independent review of the DR loan charge (‘the Review’). On 23 January 2025 the government published more details about the Review, including which DR tax avoidance arrangements the Review will consider.

You can find details of the Review online. Go to GOV.UK and search ‘new loan charge review’.

What this means for you

Based on the details published by the government and the current information we hold about you, we believe the Review will only consider some of your DR arrangements. We believe some of your DR arrangements will not be considered by the Review.

If you believe that your arrangements will not be considered by the Review or the information we hold about you may be incorrect, then please contact me as soon as possible.

Important information

We won’t be able to tell you exactly how you may be affected until (both) the:

• Review is complete, and the findings are published
• government issues its response to any Review recommendations

We’ll then write to you again to give you an update.

The information we can give you now is included in the enclosed ‘question and answer’ document.

What happens next

I’ll be your HMRC contact for any matters involving your DR arrangements and any other avoidance arrangements you may have used.

What happens next will depend on your DR arrangements and whether they will be considered by the Review.

DR arrangements considered by the Review

During the Review, I won’t contact you about these arrangements unless there are important matters such as statutory or litigation deadlines which need to be met.

If you still want to work with me to finalise your tax position for these arrangements while the Review is ongoing, please contact me.

DR arrangements not considered by the Review

For arrangements that won’t be considered by the Review, I’ll continue to work with you to finalise your tax position.

If you would prefer to wait and finalise your tax position for all DR arrangements at the same time, you can ask me to pause this work until the Review is complete. This means I won’t issue assessments or close any enquiries to finalise the amounts due for these arrangements, unless there are important matters such as statutory or litigation deadlines which need to be met. Please tell me if you want to do this when I next contact you about these arrangements.

Late payment interest

We are required to charge interest on late payments by law. We charge it on a daily basis, from the date amounts were due until the date they’re paid. This means that late payment interest will continue to build up on tax that you owe during the Review, including if we have paused or agreed with you to pause some of our work on your case.

You may want to make an upfront payment of any additional tax you owe, to stop the amount of interest building up. If we later find there’s no additional tax for you to pay, we will refund your payment (provided you don’t have other tax debts). We’ll also pay repayment interest on the amount we refund to you.

Please let me know if you want to make an upfront payment. I’ll tell you how you can pay and give you a reference number to use when paying.

If you have already agreed a payment plan to pay the tax on any of your DR arrangements, you should continue to make those payments.

Getting tax advice

If you have a tax adviser, you may want to talk to them about this letter and provide them with a copy of it.

If you don’t have a tax adviser, free advice is available from organisations such as TaxAid and Citizens Advice.

TaxAid can give tax advice to people on low incomes. For example, they can help check that a tax bill is right and deal directly with us, if needed. Citizens Advice can help people work out ways to pay the tax they owe. You can find their contact details by searching online.

If you need extra support

Please tell me if you have any health or personal circumstances that may make it difficult for you to deal with us. I’ll help you in whatever way I can.

For more information about this, go to GOV.UK and search ‘get help from HMRC if you need extra support’.

Contacting me

My contact details are included within this letter.

If you want to contact me by email, you first need to tell me in writing that you understand and accept the risks. For more information about what you need to do, please read our factsheet DSC1, ‘Corresponding with HMRC by email’. To find this factsheet, go to GOV.UK and search ‘DSC1’ or contact us and we’ll send you a copy.

Contacting us about anything else

If you want to contact us about anything else, go to GOV.UK and search ‘contact HMRC’ to find the right phone number or address.

Yours sincerely

Letter 2 – DR arrangements – considered by the Review

What you need to know about the disguised remuneration loan charge review

I’m writing to you because you have previously been paid through disguised remuneration (DR) tax avoidance arrangements.

On 30 October 2024, the government announced a new independent review of the DR loan charge (‘the Review’). On 23 January 2025 the government published more details about the Review, including which DR tax avoidance arrangements the Review will consider.

You can find details of the Review online. Go to GOV.UK and search ‘new loan charge review’.

What this means for you

Based on the details published by the government and the current information we hold about you, we believe that the Review will consider your DR arrangements.

If you believe that your arrangements will not be considered by the Review or the information we hold about you may be incorrect, then please contact me as soon as possible.

Important information

We won’t be able to tell you exactly how you may be affected until (both) the:

• Review is complete, and the findings are published
• government issues its response to any Review recommendations

We’ll then write to you again to give you an update.

The information we can give you now is included in the enclosed ‘question and answer’ document.

What happens next

I’ll be your HMRC contact for any matters involving your DR arrangements and any other avoidance arrangements you may have used.

During the Review, I won’t contact you about your DR arrangements unless there are important matters such as statutory or litigation deadlines which need to be met.

If you still want to work with me during the Review to finalise your tax position for these arrangements, please let me know.

Late payment interest

We are required to charge interest on late payments by law. We charge it on a daily basis, from the date amounts were due until the date they’re paid. This means that late payment interest will continue to build up on tax that you owe during the Review, including if we have paused or agreed with you to pause some of our work on your case.

You may want to make an upfront payment of any additional tax you owe, to stop the amount of interest building up. If we later find there’s no additional tax for you to pay, we will refund your payment (provided you don’t have other tax debts). We’ll also pay repayment interest on the amount we refund to you.

Please let me know if you want to make an upfront payment. I’ll tell you how you can pay and give you a reference number to use when paying.

If you have already agreed a payment plan to pay the tax on any of your DR arrangements, you should continue to make those payments.

Getting tax advice

If you have a tax adviser, you may want to talk to them about this letter and provide them with a copy of it.

If you don’t have a tax adviser, free advice is available from organisations such as TaxAid and Citizens Advice.

TaxAid can give tax advice to people on low incomes. For example, they can help check that a tax bill is right and deal directly with us, if needed. Citizens Advice can help people work out ways to pay the tax they owe. You can find their contact details by searching online.

If you need extra support

Please tell me if you have any health or personal circumstances that may make it difficult for you to deal with us. I’ll help you in whatever way I can.

For more information about this, go to GOV.UK and search ‘get help from HMRC if you need extra support’.

Contacting me

My contact details are included within this letter.

If you want to contact me by email, you first need to tell me in writing that you understand and accept the risks. For more information about what you need to do, please read our factsheet DSC1, ‘Corresponding with HMRC by email’. To find this factsheet, go to GOV.UK and search ‘DSC1’ or contact us and we’ll send you a copy.

Contacting us about anything else

If you want to contact us about anything else, go to GOV.UK and search ‘contact HMRC’ to find the right phone number or address.

Yours sincerely

Letter 3 – Settled DR arrangements – considered by the Review

What you need to know about the disguised remuneration loan charge review

I’m writing to you because you have previously been paid through disguised remuneration (DR) tax avoidance arrangements.

On 30 October 2024, the government announced a new independent review of the DR loan charge (‘the Review’). On 23 January 2025 the government published more details about the Review, including which DR tax avoidance arrangements the Review will consider.

You can find details of the Review online. Go to GOV.UK and search ‘new loan charge review’.

What this means for you

Based on the details published by the government and the current information we hold about you, we believe the Review will consider some or all of your DR arrangements.

If you believe that your arrangements will not be considered by the Review or the information we hold about you may be incorrect, then please contact me as soon as possible.

Important information

We won’t be able to tell you exactly how you may be affected until (both) the:

• Review is complete, and the findings are published
• government issues its response to any Review recommendations

We’ll then write to you again to give you an update.

The information we can give you now is included in the enclosed ‘question and answer’ document.

What happens next– arrangements being considered by the Review

I’ll be your HMRC contact for any matters involving your DR arrangements and any other avoidance arrangements you may have used.

We previously finalised your tax position in relation to the DR loan charge and you still have outstanding tax that you have not paid.

What you can do now depends on whether or not you’ve reached agreement with us to pay the tax. I explain more about this below.

If you have an agreement to pay

You can pause payment if you’ve already entered into an agreement with us to pay the tax. For example, if you’ve agreed a settlement that included paying by instalments or a Time to Pay arrangement.

If you tell us you want to pause payments, we won’t take any action to recover that debt until the findings of the Review are published and we know how it affects you.

Please read the section on late payment interest carefully and contact me if you want to pause payment.

If you don’t have an agreement to pay

If you haven’t reached an agreement yet to pay the tax due, please read the section on late payment interest carefully.

Late payment interest

We are required to charge interest on late payments by law. We charge it on a daily basis, from the date amounts were due until the date they’re paid. This means that late payment interest will continue to build up on tax that you owe during the Review, including if we have paused or agreed with you to pause some of our work on your case.

You may want to make an upfront payment of any additional tax you owe, to stop the amount of interest building up. If we later find there’s no additional tax for you to pay, we will refund your payment (provided you don’t have other tax debts). We’ll also pay repayment interest on the amount we refund to you.

Please let me know if you want to make an upfront payment. I’ll tell you how you can pay and give you a reference number to use when paying.

If you have already agreed a payment plan to pay the tax on any of your DR arrangements, you should continue to make those payments.

Getting tax advice

If you have a tax adviser, you may want to talk to them about this letter and provide them with a copy of it.

If you don’t have a tax adviser, free advice is available from organisations such as TaxAid and Citizens Advice.

TaxAid can give tax advice to people on low incomes. For example, they can help check that a tax bill is right and deal directly with us, if needed. Citizens Advice can help people work out ways to pay the tax they owe. You can find their contact details by searching online.

If you need extra support

Please tell me if you have any health or personal circumstances that may make it difficult for you to deal with us. I’ll help you in whatever way I can.

For more information about this, go to GOV.UK and search ‘get help from HMRC if you need extra support’.

Contacting me

My contact details are included within this letter.

If you want to contact me by email, you first need to tell me in writing that you understand and accept the risks. For more information about what you need to do, please read our factsheet DSC1, ‘Corresponding with HMRC by email’. To find this factsheet, go to GOV.UK and search ‘DSC1’ or contact us and we’ll send you a copy.

Contacting us about anything else

If you want to contact us about anything else, go to GOV.UK and search ‘contact HMRC’ to find the right phone number or address.

Yours sincerely

Letter 4 – DR arrangements – not considered by the Review

What you need to know about the disguised remuneration loan charge review

I’m writing to you because you have previously been paid through disguised remuneration (DR) tax avoidance arrangements.

On 30 October 2024, the government announced a new independent review of the DR loan charge (‘the Review’). On 23 January 2025 the government published more details about the Review, including which DR tax avoidance arrangements the Review will consider.

You can find details of the Review online. Go to GOV.UK and search ‘new loan charge review’.

What this means for you

Based on the details published by the government and the current information we hold about you, we believe that your DR arrangements will not be considered by the Review.

I’ll continue to work with you to finalise your tax position for your DR arrangements. If you believe that your arrangements will be considered by the Review, then please tell me when I next contact you about this.

I’ve enclosed a copy of our ‘question and answer’ document which gives you more information about the Review, including which arrangements the Review will be considering.

I’ll be your HMRC contact for any matters involving your DR arrangements and any other avoidance arrangements you may have used.

Late payment interest

We are required to charge interest on late payments by law. We charge it on a daily basis, from the date amounts were due until the date they’re paid. This means that late payment interest will continue to build up on tax that you owe during the Review, including if we have paused or agreed with you to pause some of our work on your case.

You may want to make an upfront payment of any additional tax you owe, to stop the amount of interest building up. If we later find there’s no additional tax for you to pay, we will refund your payment (provided you don’t have other tax debts). We’ll also pay repayment interest on the amount we refund to you.

Please let me know if you want to make an upfront payment. I’ll tell you how you can pay and give you a reference number to use when paying.

If you have already agreed a payment plan to pay the tax on any of your DR arrangements, you should continue to make those payments.

Getting tax advice

If you have a tax adviser, you may want to talk to them about this letter and provide them with a copy of it.

If you don’t have a tax adviser, free advice is available from organisations such as TaxAid and Citizens Advice.

TaxAid can give tax advice to people on low incomes. For example, they can help check that a tax bill is right and deal directly with us, if needed. Citizens Advice can help people work out ways to pay the tax they owe. You can find their contact details by searching online.

If you need extra support

Please tell me if you have any health or personal circumstances that may make it difficult for you to deal with us. I’ll help you in whatever way I can.

For more information about this, go to GOV.UK and search ‘get help from HMRC if you need extra support’.

Contacting me

My contact details are included within this letter.

If you want to contact me by email, you first need to tell me in writing that you understand and accept the risks. For more information about what you need to do, please read our factsheet DSC1, ‘Corresponding with HMRC by email’. To find this factsheet, go to GOV.UK and search ‘DSC1’ or contact us and we’ll send you a copy.

Contacting us about anything else

If you want to contact us about anything else, go to GOV.UK and search ‘contact HMRC’ to find the right phone number or address.

Yours sincerely