Question to the HM Treasury:

To ask the Chancellor of the Exchequer, with reference to the conclusions of the Morse Review, for what reason HMRC are pursuing people for pre-2010 tax years, in relation to Loan Charge legislation.

In the 2019 Independent Loan Charge Review, Lord Morse recommended that the Loan Charge should only apply to loans made on or after 9 December 2010.

However, he was also clear that, for years before this date, where there is an open enquiry or assessment under appeal, HM Revenue and Customs (HMRC) should continue with enquiries and settling cases under their normal powers.

HMRC continues to work with and support taxpayers to resolve all outstanding enquiries and assessments relating to their use of disguised remuneration (DR) loans, in accordance with their published DR settlement terms and HMRC Litigation and Settlement Strategy.