Question to the HM Treasury:

To ask the Chancellor of the Exchequer, what estimate he has made of the number of people who will be made bankrupt as a result of accelerated payment notices in respect of the 2019 Loan Charge.

The Accelerated Payment regime is designed to change the underlying economics of tax avoidance by requiring disputed tax to be paid upfront while an avoidance scheme is investigated. HMRC can only issue Accelerated Payment Notices (APNs) in tightly defined circumstances, set out in legislation.

The 2019 Loan Charge is a tax charge which applies to disguised remuneration (DR) loan balances which remained outstanding at 5 April 2019. APNs and the 2019 Loan Charge are two separate, distinct regimes. HMRC cannot issue APNs in relation to the Loan Charge.

There is no estimate on how many people will be made bankrupt as a result of APNs issued in connection with avoidance schemes that seek to disguise remuneration. HMRC do not want to make anybody bankrupt, and insolvency is only ever considered as a last resort. HMRC will work with individuals to reach sustainable and manageable payment plans wherever possible.