Question to the HM Treasury:

To ask the Chancellor of the Exchequer, how many people have been issued section 684 notices by HMRC in relation to disguised remuneration schemes in the last 12 months.

HM Revenue and Customs (HMRC) only ever considers insolvency as a last resort. Anyone who is worried about being able to pay what they owe should contact HMRC, who may be able to agree an instalment arrangement based on the individual’s financial circumstances. There is no maximum length for these arrangements.

Where people are facing insolvency, HMRC is not always the only creditor. Some individuals are declared bankrupt as a result of a non-HMRC debt and some individuals may choose to enter insolvency themselves based on their overall financial position. To date, HMRC has not initiated insolvency proceedings against any taxpayer solely for a Loan Charge debt.

As set out in the answer to PQ 17136, since 2022, HMRC has issued around 2,700 decisions under s.684(7A)(b) of the Income Tax (Earnings and Pensions) Act 2003 to disguised remuneration scheme users.