Question to the HM Treasury:

To ask the Chancellor of the Exchequer, what assessment she has made of the effectiveness of the application of the Litigation and Settlement Strategy on settlements made following disguised renumeration schemes.

The Government commissioned an independent review of the loan charge to help bring the matter to a close for those affected whilst ensuring fairness for all taxpayers. The Government will respond by Autumn Budget 2025.

The Litigation and Settlement Strategy (LSS) ensures that HMRC applies the law fairly and consistently. The LSS applies as much to the resolution of a dispute with a multinational corporation as it does to small business customers or individuals. This ensures every taxpayer, no matter who they are, pays the tax due under the law.

Central to the LSS is that HMRC will not settle a dispute by agreement for an amount which is less than it would reasonably expect to obtain from litigation.