Question to the HM Treasury:

To ask the Chancellor of the Exchequer, what recent representations has he received on section 684 notices.

In May 2022, the Court of Appeal confirmed that HMRC could use provisions in tax legislation (section 684(7A)(b) of the Income Tax (Earnings and Pensions) Act 2003). HMRC is using these provisions in line with the Court of Appeal judgment.

The Government has received representations about s684(7A)(b) from several Members on behalf of their constituents, as well as the All Party Parliamentary Group on the Loan Charge and Taxpayer Fairness.