HMRC activity during the Loan Charge review

24 January 2025

HM Revenue and Customs (HMRC) has released a policy paper outlining the steps they will be taking, and what affected taxpayers should know, while the Loan Charge review is underway.

Use of disguised remuneration (DR) arrangements

HMRC have stated that individuals with outstanding amounts relating to the use of disguised remuneration (DR) arrangements will be contacted by mid-March. The contact will:

• assign them a named HMRC contact
• set out whether HMRC think the DR arrangements they used will be considered by the review or not
• explain what the next steps are for customers.

The HMRC policy paper breakdown of DR arrangements

The policy paper sets out the operation approach to three different groups:

1. Customers who have used DR arrangements that HMRC believe will be considered by the review
2. Customers who have used DR arrangements that HMRC believe will not be considered by the review
3. Customers who have used multiple DR arrangements, only some of which HMRC believe will be considered by the review

as well as the requirements to charge interest and links to independent advice.

• HMRC General
• Tax avoidance and evasion

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