Independent loan charge reviews

Produced by a Tolley Employment Tax expert

Employment Tax

Guidance

The ‘loan charge’ is a liability which attached to loans made to employees and directors via certain so called ‘disguised remuneration’ schemes. Liabilities which HMRC argued were due but remained unpaid at 5 April 2019, were identified as definitive liabilities by virtue of a new ‘loan charge’ legislation. See the Loan charge guidance note for further details.

However, the loan charge legislation was considered by many as unfair and, at best, something of a blunt force tool. This has led to two separate independent reviews of the loan charge, details of which are the subject of this particular guidance note.

2025 further loan charge review

A new and independent review into the loan charge was launched in January 2025. This is due to report in Summer 2025. The review will examine the barriers preventing those who are subject to the loan charge but have not already settled and paid their tax liabilities in full from reaching resolution with HMRC. It will recommend ways in which they can be encouraged to settle with HMRC. See the Written Ministerial

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