Question to the HM Treasury:

To ask the Chancellor of the Exchequer, whether she plans to review Section 684 activities with reference to the Loan Charge.

Section 684 of the Income Tax (Earnings and Pensions) Act (ITEPA) 2003 provides for the Pay As You Earn (PAYE) regulations. In 2022, the Court of Appeal considered HMRC’s use of section 684(7A)(b) in relation to a disguised remuneration scheme.

The Chancellor and I know that the loan charge is a very important matter for many members and their constituents. We have been considering this matter since taking office and will provide an update in due course.