Asked by: Roz Savage (Liberal Democrat - South Cotswolds)
Question to the HM Treasury:
To ask the Chancellor of the Exchequer, what estimate she has made of the timescale for resolving outstanding cases involving individuals subject to the Loan Charge that will be settled following the conclusions of the independent review led by Ray McCann.
Answered by Dan Tomlinson - Exchequer Secretary (HM Treasury)
This Government recognised that concerns were raised about the Loan Charge under the previous government and that some felt strongly that it had not been handled appropriately.
The Government therefore commissioned an independent review of the loan charge to bring the matter to a close for those who had not settled and paid their loan charge liabilities. The Government accepted the review’s conclusion that the loan charge was an extraordinary piece of Government policy which necessitated an exceptional response, and is now legislating to give HMRC the power to administer a new settlement opportunity.
To encourage more people to settle, the Government will write off the first £5,000 of liabilities in addition to the proposals put forward by Ray McCann. As a result, most individuals could see reductions of at least 50% in their outstanding loan charge liabilities, and an estimated 30% of individuals could have these liabilities written off entirely.
HMRC began contacting taxpayers to notify them of their eligibility for the new settlement opportunity from January 2026. HMRC will begin contacting them again, from Spring, to explain the settlement opportunity in more detail. HMRC will contact taxpayers in stages and all taxpayers in scope will be invited to settle by the end of the 2027-28 tax year.
HMRC will encourage taxpayers who want to settle to contact their named HMRC caseworker proactively, and not to wait for a letter. Taxpayers that contact HMRC will be prioritised for settlement.
Asked by: Luke Taylor (Liberal Democrat - Sutton and Cheam)
Question to the HM Treasury:
To ask the Chancellor of the Exchequer, how she plans to undertake loan charge settlement for those impacted prior to December 2010.
Answered by Dan Tomlinson - Exchequer Secretary (HM Treasury)
This Government recognised that concerns continued to be raised about the loan charge and that some felt strongly that this had not been handled appropriately. The Government therefore commissioned an independent review of the loan charge to bring the matter to a close for those affected, ensure fairness for all taxpayers and ensure that appropriate support is in place for those subject to the loan charge.
The settlement opportunity will only include disguised remuneration scheme use between December 2010 and April 2019 because this is the period during which the loan charge applies.
The settlement opportunity will not apply to other tax avoidance schemes that are not within scope of the loan charge. In those cases, HMRC will continue to work with taxpayers to resolve their cases in line with existing legislation and case law. HMRC is committed to working sensitively and pragmatically with taxpayers to reach settlement. This includes by offering flexible payment terms where people need more time to pay their liabilities.
Asked by: Lisa Smart (Liberal Democrat - Hazel Grove)
Question to the HM Treasury:
To ask the Chancellor of the Exchequer, how many individuals with outstanding Loan Charge liabilities are estimated to have debts exceeding £140,000; and of those, how many she expects will be able to settle under the terms announced following the McCann Review.
Answered by Dan Tomlinson - Exchequer Secretary (HM Treasury)
This Government recognised that concerns were raised about the Loan Charge under the previous government and that some felt strongly that it had not been handled appropriately.
The Government therefore commissioned an independent review of the Loan Charge to bring the matter to a close for those affected, ensure fairness for all taxpayers and ensure that appropriate support is in place for those subject to the Loan Charge.
Page 19 of the Independent Loan Charge Review report provides estimates of the distribution of outstanding liabilities.
https://www.gov.uk/government/publications/independent-review-of-the-loan-charge
The Government accepted all but one of the independent review’s recommendations and in some cases is going further, including writing off the first £5,000 from everyone’s liability. Around a third will have their liabilities written off entirely. Most people will see reductions in their liabilities of at least 50%.
The new settlement opportunity is open to anyone with outstanding Loan Charge liabilities, including employers.
The Government’s response to the review represents a fair and proportionate attempt to provide a route to resolution for those who have not yet been able to settle with HMRC. In turn, this requires those individuals to now come forward and engage with HMRC in good faith.
Asked by: Lisa Smart (Liberal Democrat - Hazel Grove)
Question to the HM Treasury:
To ask the Chancellor of the Exchequer, for what reason the settlement opportunity arising from the McCann Review does not include those whose use of disguised remuneration schemes occurred before 9 December 2010 or after 5 April 2019.
Answered by Dan Tomlinson - Exchequer Secretary (HM Treasury)
At Budget 2024, the Government announced a new independent review of the loan charge. The purpose of the review was to bring the matter to a close for people who have not settled and paid their loan charge liabilities.
The settlement opportunity will only include disguised remuneration scheme use between December 2010 and April 2019 because this is the period during which the loan charge applies.
The Government has no plans to apply the review’s recommendations beyond those individuals and employers with outstanding liabilities that were the focus of the review.
Asked by: Jess Brown-Fuller (Liberal Democrat - Chichester)
Question to the HM Treasury:
To ask the Chancellor of the Exchequer, how many individuals in (a) the Chichester constituency and (b) the UK have been issued tax demands under the Loan Charge policy; and what estimate she has made of the total value of those demands.
Answered by Dan Tomlinson - Exchequer Secretary (HM Treasury)
Information on the number of individuals subject to the Loan Charge is not held at constituency, borough or regional level.
HMRC’s estimate of the number of individuals that are affected by the Loan Charge policy is around 45,000. Some of these individuals have already settled with HMRC.
The Government commissioned an independent review of the Loan Charge to bring the matter to a close for those affected, ensure fairness for all taxpayers and ensure that appropriate support is in place for those subject to the loan charge.
The Government accepted the review’s conclusion that the Loan Charge was an extraordinary piece of Government policy which necessitated an exceptional response, and is now legislating a new settlement opportunity that will assist those who have not yet settled to do so.
The Government’s response to the review represents a fair and proportionate attempt to provide a route to resolution for those who have not yet been able to settle with HMRC. In turn, this requires those individuals to now come forward and engage with HMRC.
Asked by: John McDonnell (Labour - Hayes and Harlington)
Question to the HM Treasury:
To ask the Chancellor of the Exchequer, what steps HMRC is taking to support people affected by the Loan Charge.
Answered by Dan Tomlinson - Exchequer Secretary (HM Treasury)
This Government recognised that concerns continued to be raised about the loan charge and that some felt strongly that it had not been handled appropriately.
The Government therefore commissioned an independent review of the loan charge to bring the matter to a close for those affected, ensure fairness for all taxpayers and ensure that appropriate support is in place for those subject to the loan charge.
The Government accepted the review’s conclusion that the loan charge was an extraordinary piece of Government policy which necessitated an exceptional response, and is now legislating to give HMRC the power to administer a new settlement opportunity.
To encourage more people to settle, the Government will write off the first £5,000 of liabilities in addition to the proposals put forward by Ray McCann. As a result, most individuals could see reductions of at least 50% in their outstanding loan charge liabilities, and an estimated 30% of individuals could have these liabilities written off entirely.
The Government’s response to the review represents a fair and proportionate attempt to provide a route to resolution for those who have not yet been able to settle with HMRC. In turn, this requires those individuals to now come forward and engage with HMRC in good faith.
HMRC is committed to working sensitively and pragmatically with taxpayers to reach settlement. This includes offering flexible payment terms where people need more time to pay their liabilities.
The Government takes the wellbeing of all taxpayers very seriously. Vulnerable customers can make use of HMRC’s well-established Extra Support Service.
Asked by: Manuela Perteghella (Liberal Democrat - Stratford-on-Avon)
Question to the HM Treasury:
To ask the Chancellor of the Exchequer, what assessment she has made of the effectiveness of HMRC’s approach to dealing with disguised remuneration schemes.
Answered by Dan Tomlinson - Exchequer Secretary (HM Treasury)
This government recognised that concerns continued to be raised about the loan charge and that some felt strongly that it had not been handled appropriately.
The Government therefore commissioned an independent review of the loan charge to bring the matter to a close for those affected, ensure fairness for all taxpayers and ensure that appropriate support is in place for those subject to the loan charge.
The Government accepted the review’s conclusion that the loan charge was an extraordinary piece of Government policy which necessitated an exceptional response, and is now legislating a new settlement opportunity that will assist those who have not yet settled to do so.
To encourage more people to settle, the Government will write off the first £5,000 of liabilities in addition to the proposals put forward by Ray McCann. As a result, most individuals could see reductions of at least 50% in their outstanding loan charge liabilities, and an estimated 30% of individuals could have these liabilities written off entirely.
The Government’s response to the review represents a fair and proportionate attempt to provide a route to resolution for those who have not yet settled with HMRC. In turn, this requires those individuals to now come forward and engage with HMRC in good faith.
Tax avoidance deprives the Exchequer of funds needed to deliver vital public services and it is right that resources are targeted to stop this. There are no plans to apply the review’s recommendations beyond those individuals and employers with outstanding liabilities that were the focus of the review.
At the Budget, the Government announced action to tackle tax avoidance by umbrella companies, where most disguised remuneration now takes place. The Government is introducing legislation, effective from April 2026, to make recruitment agencies using umbrella companies legally responsible for accounting for PAYE on workers’ pay. Where there is no agency in the supply chain, this responsibility will fall to the end client.
The Government is also introducing new powers in Finance Bill 2025/26 to close in on promoters of marketed tax avoidance and the other professionals who market or enable tax avoidance schemes.
These new powers will go further and include more criminal sanctions. This shows the Government’s clear determination to close in on the few remaining promoters by strengthening deterrents and introducing significant additional consequences for promoters who continue promoting tax avoidance schemes.
HM Revenue and Customs (HMRC) has brought into charge more than £4 billion from its work tackling disguised remuneration.
Asked by: John McDonnell (Labour - Hayes and Harlington)
Question to the HM Treasury:
To ask the Chancellor of the Exchequer, what steps she is taking to ensure that HMRC adequately interprets the provisions of the (a) McCann report and the (b) Government's response, in the context of support for people affected by the Loan Charge.
Answered by Dan Tomlinson - Exchequer Secretary (HM Treasury)
This Government recognised that concerns continued to be raised about the loan charge and that some felt strongly that it had not been handled appropriately.
The Government therefore commissioned an independent review of the loan charge to bring the matter to a close for those affected, ensure fairness for all taxpayers and ensure that appropriate support is in place for those subject to the loan charge.
The Government accepted the review’s conclusion that the loan charge was an extraordinary piece of Government policy which necessitated an exceptional response, and is now legislating to give HMRC the power to administer a new settlement opportunity.
To encourage more people to settle, the Government will write off the first £5,000 of liabilities in addition to the proposals put forward by Ray McCann. As a result, most individuals could see reductions of at least 50% in their outstanding loan charge liabilities, and an estimated 30% of individuals could have these liabilities written off entirely.
The Government’s response to the review represents a fair and proportionate attempt to provide a route to resolution for those who have not yet been able to settle with HMRC. In turn, this requires those individuals to now come forward and engage with HMRC in good faith.
HMRC is committed to working sensitively and pragmatically with taxpayers to reach settlement. This includes offering flexible payment terms where people need more time to pay their liabilities.
The Government takes the wellbeing of all taxpayers very seriously. Vulnerable customers can make use of HMRC’s well-established Extra Support Service.
Asked by: Manuela Perteghella (Liberal Democrat - Stratford-on-Avon)
Question to the HM Treasury:
To ask the Chancellor of the Exchequer, if she will offer the same settlement terms that will be provided in the settlement opportunity resulting from the implementation of the McCann Review to those that have already settled with HMRC.
Answered by Dan Tomlinson - Exchequer Secretary (HM Treasury)
This government recognised that concerns continued to be raised about the loan charge and that some felt strongly that it had not been handled appropriately.
The Government therefore commissioned an independent review of the loan charge to bring the matter to a close for those affected, ensure fairness for all taxpayers and ensure that appropriate support is in place for those subject to the loan charge.
The Government accepted the review’s conclusion that the loan charge was an extraordinary piece of Government policy which necessitated an exceptional response, and is now legislating a new settlement opportunity that will assist those who have not yet settled to do so.
To encourage more people to settle, the Government will write off the first £5,000 of liabilities in addition to the proposals put forward by Ray McCann. As a result, most individuals could see reductions of at least 50% in their outstanding loan charge liabilities, and an estimated 30% of individuals could have these liabilities written off entirely.
The Government’s response to the review represents a fair and proportionate attempt to provide a route to resolution for those who have not yet settled with HMRC. In turn, this requires those individuals to now come forward and engage with HMRC in good faith.
Tax avoidance deprives the Exchequer of funds needed to deliver vital public services and it is right that resources are targeted to stop this. There are no plans to apply the review’s recommendations beyond those individuals and employers with outstanding liabilities that were the focus of the review.
At the Budget, the Government announced action to tackle tax avoidance by umbrella companies, where most disguised remuneration now takes place. The Government is introducing legislation, effective from April 2026, to make recruitment agencies using umbrella companies legally responsible for accounting for PAYE on workers’ pay. Where there is no agency in the supply chain, this responsibility will fall to the end client.
The Government is also introducing new powers in Finance Bill 2025/26 to close in on promoters of marketed tax avoidance and the other professionals who market or enable tax avoidance schemes.
These new powers will go further and include more criminal sanctions. This shows the Government’s clear determination to close in on the few remaining promoters by strengthening deterrents and introducing significant additional consequences for promoters who continue promoting tax avoidance schemes.
HM Revenue and Customs (HMRC) has brought into charge more than £4 billion from its work tackling disguised remuneration.
Asked by: Manuela Perteghella (Liberal Democrat - Stratford-on-Avon)
Question to the HM Treasury:
To ask the Chancellor of the Exchequer, what assessment she has made of the value-for-money to the taxpayer of the Loan Charge.
Answered by Dan Tomlinson - Exchequer Secretary (HM Treasury)
This government recognised that concerns continued to be raised about the loan charge and that some felt strongly that it had not been handled appropriately.
The Government therefore commissioned an independent review of the loan charge to bring the matter to a close for those affected, ensure fairness for all taxpayers and ensure that appropriate support is in place for those subject to the loan charge.
The Government accepted the review’s conclusion that the loan charge was an extraordinary piece of Government policy which necessitated an exceptional response, and is now legislating a new settlement opportunity that will assist those who have not yet settled to do so.
To encourage more people to settle, the Government will write off the first £5,000 of liabilities in addition to the proposals put forward by Ray McCann. As a result, most individuals could see reductions of at least 50% in their outstanding loan charge liabilities, and an estimated 30% of individuals could have these liabilities written off entirely.
The Government’s response to the review represents a fair and proportionate attempt to provide a route to resolution for those who have not yet settled with HMRC. In turn, this requires those individuals to now come forward and engage with HMRC in good faith.
Tax avoidance deprives the Exchequer of funds needed to deliver vital public services and it is right that resources are targeted to stop this. There are no plans to apply the review’s recommendations beyond those individuals and employers with outstanding liabilities that were the focus of the review.
At the Budget, the Government announced action to tackle tax avoidance by umbrella companies, where most disguised remuneration now takes place. The Government is introducing legislation, effective from April 2026, to make recruitment agencies using umbrella companies legally responsible for accounting for PAYE on workers’ pay. Where there is no agency in the supply chain, this responsibility will fall to the end client.
The Government is also introducing new powers in Finance Bill 2025/26 to close in on promoters of marketed tax avoidance and the other professionals who market or enable tax avoidance schemes.
These new powers will go further and include more criminal sanctions. This shows the Government’s clear determination to close in on the few remaining promoters by strengthening deterrents and introducing significant additional consequences for promoters who continue promoting tax avoidance schemes.
HM Revenue and Customs (HMRC) has brought into charge more than £4 billion from its work tackling disguised remuneration.