Question to the HM Treasury:

To ask the Chancellor of the Exchequer, how many people HM Revenue and Customs was seeking loan charge payments from in relation to the tax years before April 2010, as of 8 September 2023.

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. The Government accepted this recommendation.

However, Lord Morse 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 still have the ability to pursue the tax due under the existing rules. HMRC has proceeded on this basis.

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’s Litigation and Settlement Strategy.