Question to the HM Treasury:

To ask the Chancellor of the Exchequer, pursuant to the Answer of 23 February 2023 to Question 147156 on Tax Avoidance: how many (a) open enquiries and (b) active assessments relating to disguised remuneration schemes used before 9 December 2010 are outstanding.

HM Revenue and Customs currently has around 15,000 open compliance checks in respect of individual taxpayers who used DR tax avoidance schemes before 9 December 2010, and which are not subject to the Loan charge following recommendations made by the Independent Loan Charge Review. These compliance checks will include both open enquiries and assessments. An individual may have more than one compliance check depending on their scheme usage and whether it spans more than one tax year.

Taxpayers who wish to settle, whether or not the loan charge applies, can do so under the DR settlement terms 2020 which are published on GOV.UK. Taxpayers who do not wish to settle the tax due in respect of their DR scheme use under the published terms have the option of taking their cases before the tribunals and courts.