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Written Question
Tax Avoidance
Wednesday 14th October 2020

Asked by: David Davis (Conservative - Goole and Pocklington)

Question to the HM Treasury:

To ask the Chancellor of the Exchequer, what criteria HM Revenue and Customs use to decide whether individual Loan Charge settlement discussions can continue past the 30 September settlement deadline.

Answered by Jesse Norman - Shadow Leader of the House of Commons

At the time of the independent review of the Loan Charge, about 12,000 employers and individuals had the opportunity to avoid the Loan Charge by concluding settlements, having provided all the relevant information to HMRC by 5 April 2019. Early indications are that as at 2 October about 60 percent of these taxpayers have either settled, informed HMRC that they had instead decided to report and pay the Loan Charge, or have been taken out of scope of the Loan Charge following the Government’s changes in response to the independent review.

HMRC are continuing settlement discussions with a relatively small number of taxpayers who were prevented from meeting the 30 September deadline by exceptional circumstances beyond their control, such as recent hospitalisation. HMRC’s criteria for continuing settlement discussions beyond the 30 September deadline are:

  • The taxpayer had actively engaged in the settlement process until the occurrence of a factor, and
  • The factor is entirely outside the control of the taxpayer, and
  • The factor prevented the taxpayer from settling by 30 September, and
  • Absent the factor, the taxpayer would have been able to settle by 30 September, and
  • The taxpayer will be able, and agrees, to settle within a defined period of no more than 3 months after the 30 September.

HMRC do not hold aggregate data on when individual taxpayers were issued with settlement offers.


Written Question
Tax Avoidance
Wednesday 14th October 2020

Asked by: David Davis (Conservative - Goole and Pocklington)

Question to the HM Treasury:

To ask the Chancellor of the Exchequer, how many people subject to the Loan Charge were offered settlements (a) four weeks, (b) three weeks, (c) two weeks, (d) one week and (e) less than one week before the 30 September settlement deadline.

Answered by Jesse Norman - Shadow Leader of the House of Commons

At the time of the independent review of the Loan Charge, about 12,000 employers and individuals had the opportunity to avoid the Loan Charge by concluding settlements, having provided all the relevant information to HMRC by 5 April 2019. Early indications are that as at 2 October about 60 percent of these taxpayers have either settled, informed HMRC that they had instead decided to report and pay the Loan Charge, or have been taken out of scope of the Loan Charge following the Government’s changes in response to the independent review.

HMRC are continuing settlement discussions with a relatively small number of taxpayers who were prevented from meeting the 30 September deadline by exceptional circumstances beyond their control, such as recent hospitalisation. HMRC’s criteria for continuing settlement discussions beyond the 30 September deadline are:

  • The taxpayer had actively engaged in the settlement process until the occurrence of a factor, and
  • The factor is entirely outside the control of the taxpayer, and
  • The factor prevented the taxpayer from settling by 30 September, and
  • Absent the factor, the taxpayer would have been able to settle by 30 September, and
  • The taxpayer will be able, and agrees, to settle within a defined period of no more than 3 months after the 30 September.

HMRC do not hold aggregate data on when individual taxpayers were issued with settlement offers.


Written Question
Tax Avoidance: Mental Health and Suicide
Wednesday 14th October 2020

Asked by: David Davis (Conservative - Goole and Pocklington)

Question to the HM Treasury:

To ask the Chancellor of the Exchequer, what assessment he has made of the effect of his Department's decision not to extend the Loan Charge settlement deadline on the (a) mental health of and (b) risk of suicide in people subject to the Loan Charge.

Answered by Jesse Norman - Shadow Leader of the House of Commons

The Government announced in December 2019 that it would extend the Loan Charge deadline from 31 January 2020 to 30 September 2020, for individuals due to pay the Loan Charge to submit their 2018/19 Self Assessment returns and pay the tax due or agree a time to pay arrangement.

The Government takes concerns over the physical and mental wellbeing of taxpayers very seriously. These cases are complex and typically involve many different factors.

HMRC have signposted the extra help available to taxpayers in correspondence and on calls. Their staff are trained to detect signs of stress, and look out for indications that a taxpayer may need extra support; and where appropriate will transfer them to an Extra Support adviser who has additional skills, knowledge and tools to help them. Where appropriate, HMRC also refer taxpayers to expert outside organisations that can provide further independent advice and support.


Written Question
Tax Avoidance
Wednesday 14th October 2020

Asked by: David Davis (Conservative - Goole and Pocklington)

Question to the HM Treasury:

To ask the Chancellor of the Exchequer, whether any recipient of Loan Charge settlement letters has received letters containing confidential information belonging to other people.

Answered by Jesse Norman - Shadow Leader of the House of Commons

HMRC take taxpayer confidentiality seriously. Of the tens of thousands of items of communication that HMRC have sent to taxpayers in recent months about their disguised remuneration usage, HMRC are aware of fewer than 10 occasions where confidential information was sent to the wrong taxpayer in error. In these circumstances HMRC follow the necessary processes to undertake corrective action.

HMRC issue settlement calculations to those who have come forward to settle their tax affairs based on the information they provided to HMRC. The settlement offer letter explains that they can ask HMRC to reconsider the calculations if they believe the figures set out in the letter are not correct.

To maintain a consistent approach, the terms of any settlement opportunity must fall within HMRC’s published Litigation and Settlement Strategy and apply equally to all those who may wish to take up the opportunity. As set out in the Litigation and Settlement Strategy, HMRC will only settle for an amount that is consistent with the law.


Written Question
Tax Avoidance
Wednesday 14th October 2020

Asked by: David Davis (Conservative - Goole and Pocklington)

Question to the HM Treasury:

To ask the Chancellor of the Exchequer, how HM Revenue and Customs calculates loan charge settlement offers; and what processes are in place to ensure all loan charge settlement offers are calculated consistently.

Answered by Jesse Norman - Shadow Leader of the House of Commons

HMRC take taxpayer confidentiality seriously. Of the tens of thousands of items of communication that HMRC have sent to taxpayers in recent months about their disguised remuneration usage, HMRC are aware of fewer than 10 occasions where confidential information was sent to the wrong taxpayer in error. In these circumstances HMRC follow the necessary processes to undertake corrective action.

HMRC issue settlement calculations to those who have come forward to settle their tax affairs based on the information they provided to HMRC. The settlement offer letter explains that they can ask HMRC to reconsider the calculations if they believe the figures set out in the letter are not correct.

To maintain a consistent approach, the terms of any settlement opportunity must fall within HMRC’s published Litigation and Settlement Strategy and apply equally to all those who may wish to take up the opportunity. As set out in the Litigation and Settlement Strategy, HMRC will only settle for an amount that is consistent with the law.


Written Question
Tax Avoidance: Coronavirus
Wednesday 14th October 2020

Asked by: David Davis (Conservative - Goole and Pocklington)

Question to the HM Treasury:

To ask the Chancellor of the Exchequer, what arrangements HM Revenue and Customs been put in place for people subject to the Loan Charge who are experiencing financial hardship as a result of the coronavirus outbreak.

Answered by Jesse Norman - Shadow Leader of the House of Commons

The Government and Her Majesty’s Revenue and Customs (HMRC) are acutely aware of the current economic challenges facing taxpayers as a result of the COVID-19 outbreak.

HMRC have a strong, established approach to supporting those who are unable to pay the tax they owe in full, through payment arrangements for those who reach a settlement agreement with HMRC, and Time to Pay (TTP) arrangements which are available for those paying the Loan Charge. These are tailored to each individual’s financial circumstances.

Anyone worried about their ability to pay tax owed, as a result of a change in their financial circumstances, should get in touch with HMRC as soon as possible. A TTP arrangement is designed to be flexible and is not a fixed contract. It can be amended over time in order to enable HMRC to lengthen the arrangement if expenses increase or income decreases.

HMRC are also able to refer taxpayers to an external body to provide independent advice on options available to people who are unable to pay or are in difficulty with their debts.


Speech in Commons Chamber - Wed 01 Jul 2020
Finance Bill

"I rise to speak to the amendments and new clauses tabled in my name and the names of other Members of this House. They include new clause 31 and the consequential amendments relating to the loan charge legislation, and amendment 20 and the consequential amendments relating to the application of …..."
David Davis - View Speech

View all David Davis (Con - Goole and Pocklington) contributions to the debate on: Finance Bill

Speech in Commons Chamber - Wed 01 Jul 2020
Finance Bill

"The right hon. Gentleman makes a good point, but he should make it to the Speaker rather than me, as he well knows. He has been a Member nearly as long as I have...."
David Davis - View Speech

View all David Davis (Con - Goole and Pocklington) contributions to the debate on: Finance Bill

Speech in Commons Chamber - Wed 01 Jul 2020
Finance Bill

"Thank you, Mr Deputy Speaker. I shall move on to the other issue that I want to discuss today.

Amendment 20 would delay the imposition of the IR35 rules from 2021 until April 2023. It is very unlikely that the economic crisis we are facing will be over by April …..."

David Davis - View Speech

View all David Davis (Con - Goole and Pocklington) contributions to the debate on: Finance Bill

Speech in Commons Chamber - Wed 01 Jul 2020
Finance Bill

"If my hon. Friend thinks that this is the precedent, he should go back to the Finance Act 2008, which gives HMRC a 20-year assessment period in which it can assess whether the taxpayer participated in a transaction knowing that it was part of an arrangement attempting to bring about …..."
David Davis - View Speech

View all David Davis (Con - Goole and Pocklington) contributions to the debate on: Finance Bill