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.

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.