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Written Question
Disguised Remuneration Loan Charge Review
Friday 7th March 2025

Asked by: James Frith (Labour - Bury North)

Question to the HM Treasury:

To ask the Chancellor of the Exchequer, for what reason the Loan Charge review does not include the (a) role and (b) conduct of people who profited from recommending and operating disguised remuneration schemes in its scope.

Answered by James Murray - Exchequer Secretary (HM Treasury)

The government has commissioned an independent review of the Loan Charge to help bring the matter to a close for those affected whilst ensuring fairness for all taxpayers.

The Government is committed to tackling promoters of tax avoidance and will consult on measures to tackle promoters of marketed tax avoidance, including new powers focused on those who own or control promoter organisations and options to tackle legal professionals behind avoidance schemes.

The Government announced action at 2024 Autumn Budget to tackle tax avoidance by umbrella companies. Legislation, effective from April 2026, will be introduced 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. This along with the measures on promoters will help prevent disguised remuneration in the future.

In relation to the prosecution of Loan Charge scheme promoters and operators, I refer the hon. Member for Bury North to the answer I gave on 16 October 2024 to Question UIN 7747.


Written Question
Independent Review of the Loan Charge
Monday 10th February 2025

Asked by: Julian Lewis (Conservative - New Forest East)

Question to the HM Treasury:

To ask the Chancellor of the Exchequer, whether she made an assessment of the potential merits of including within the terms of reference for the Independent Review of the Loan Charge consideration of the (a) mis-selling by scheme promoters, (b) advice on legality given by accountants, (c) impact of retrospective pursuit on mental health and welfare and (d) measures for protection against recurrence in future; and if she will take steps to revise the terms of reference to include those matters.

Answered by James Murray - Exchequer Secretary (HM Treasury)

On 23 January, the Government launched the Independent Review of the Loan Charge, honouring a commitment made at the Budget.

The objectives of the review are to help 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 terms of reference for the review have been published here: www.gov.uk/government/publications/independent-review-of-the-loan-charge.

As I set out in my letter to the reviewer, we want the review to bring the Loan Charge to a close for those people who still owe substantial amounts of money but can see no way to resolve their debts. It is now for the reviewer to conduct his review and make recommendations to the Government.

The Government is also taking action to prevent disguised remuneration in the future. At the Budget, the Government announced the most ambitious ever package to close the tax gap, raising £6.5 billion of additional tax revenue in 2029-30. The package includes measures to tackle promoters of tax avoidance schemes and to address non-compliance in umbrella companies, where most disguised remuneration now takes place.


Written Statements
Loan Charge: Independent Review - Thu 23 Jan 2025
HM Treasury

Mentions:
1: James Murray (LAB - Ealing North) At the Budget, the Government announced that they would commission an independent review of the loan - Speech Link


Written Question
Tax Avoidance
Friday 7th March 2025

Asked by: James Frith (Labour - Bury North)

Question to the HM Treasury:

To ask the Chancellor of the Exchequer, what assessment she has made of the role of umbrella companies in the use of disguised remuneration schemes.

Answered by James Murray - Exchequer Secretary (HM Treasury)

The government has commissioned an independent review of the Loan Charge to help bring the matter to a close for those affected whilst ensuring fairness for all taxpayers.

The Government is committed to tackling promoters of tax avoidance and will consult on measures to tackle promoters of marketed tax avoidance, including new powers focused on those who own or control promoter organisations and options to tackle legal professionals behind avoidance schemes.

The Government announced action at 2024 Autumn Budget to tackle tax avoidance by umbrella companies. Legislation, effective from April 2026, will be introduced 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. This along with the measures on promoters will help prevent disguised remuneration in the future.

In relation to the prosecution of Loan Charge scheme promoters and operators, I refer the hon. Member for Bury North to the answer I gave on 16 October 2024 to Question UIN 7747.


Written Question
Tax Avoidance
Friday 7th March 2025

Asked by: James Frith (Labour - Bury North)

Question to the HM Treasury:

To ask the Chancellor of the Exchequer, what assessment she has made of the role of recruitment companies in the use of disguised remuneration schemes.

Answered by James Murray - Exchequer Secretary (HM Treasury)

The government has commissioned an independent review of the Loan Charge to help bring the matter to a close for those affected whilst ensuring fairness for all taxpayers.

The Government is committed to tackling promoters of tax avoidance and will consult on measures to tackle promoters of marketed tax avoidance, including new powers focused on those who own or control promoter organisations and options to tackle legal professionals behind avoidance schemes.

The Government announced action at 2024 Autumn Budget to tackle tax avoidance by umbrella companies. Legislation, effective from April 2026, will be introduced 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. This along with the measures on promoters will help prevent disguised remuneration in the future.

In relation to the prosecution of Loan Charge scheme promoters and operators, I refer the hon. Member for Bury North to the answer I gave on 16 October 2024 to Question UIN 7747.


Written Question
Tax Avoidance
Friday 7th March 2025

Asked by: James Frith (Labour - Bury North)

Question to the HM Treasury:

To ask the Chancellor of the Exchequer, what assessment she has made of the contribution of (a) accountants and (b) tax advisers to disguised remuneration schemes.

Answered by James Murray - Exchequer Secretary (HM Treasury)

The government has commissioned an independent review of the Loan Charge to help bring the matter to a close for those affected whilst ensuring fairness for all taxpayers.

The Government is committed to tackling promoters of tax avoidance and will consult on measures to tackle promoters of marketed tax avoidance, including new powers focused on those who own or control promoter organisations and options to tackle legal professionals behind avoidance schemes.

The Government announced action at 2024 Autumn Budget to tackle tax avoidance by umbrella companies. Legislation, effective from April 2026, will be introduced 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. This along with the measures on promoters will help prevent disguised remuneration in the future.

In relation to the prosecution of Loan Charge scheme promoters and operators, I refer the hon. Member for Bury North to the answer I gave on 16 October 2024 to Question UIN 7747.


Non-Departmental Publication (Policy paper)
HM Revenue & Customs

Jan. 23 2025

Source Page: HMRC issue briefing: operational activity during the new independent review of the Loan Charge
Document: HMRC issue briefing: operational activity during the new independent review of the Loan Charge (webpage)

Found: of the Loan Charge This briefing explains HMRC's operational activity during the new independent


Written Question
Independent Review of the Loan Charge
Monday 10th March 2025

Asked by: Pippa Heylings (Liberal Democrat - South Cambridgeshire)

Question to the HM Treasury:

To ask the Chancellor of the Exchequer, if she will have discussions with Ray McCann on including the role of people who (a) recommended and (b) operated disguised remuneration schemes with the Loan Charge review.

Answered by James Murray - Exchequer Secretary (HM Treasury)

The Government has commissioned an independent review of the Loan Charge to help bring the matter to a close for those affected whilst ensuring fairness for all taxpayers.

The Government does not think it is right for people affected by the Loan Charge to have to wait years for any progress on bringing this matter to a close for them. The Government has therefore ensured that the review has a focused remit, allowing it to report by this summer. The Government will respond by Autumn Budget 2025.

Alongside the review, the Government is committed to tackling promoters of tax avoidance and will consult on measures to tackle promoters of marketed tax avoidance, including new powers focused on those who own or control promoter organisations and options to tackle legal professionals behind avoidance schemes.


Written Question
Tax Avoidance
Wednesday 7th May 2025

Asked by: Angus MacDonald (Liberal Democrat - Inverness, Skye and West Ross-shire)

Question to the HM Treasury:

To ask the Chancellor of the Exchequer, if her Department will make promoters of disguised remuneration schemes jointly liable for Loan Charge tax liabilities.

Answered by James Murray - Exchequer Secretary (HM Treasury)

The Government has commissioned an independent review of the Loan Charge. The review has a focused remit, allowing it to report by this summer and the Government will respond by Autumn Budget 2025.

Alongside the review, on 30 October 2024, the Government announced further measures to tackle promoters of marketed tax avoidance. On 26 March 2025 a consultation document was published setting out proposals to tackle these promoters. The Government has also already announced measures to tackle the significant tax avoidance and fraud in the umbrella company market.


Written Question
Tax Avoidance
Friday 7th March 2025

Asked by: James Frith (Labour - Bury North)

Question to the HM Treasury:

To ask the Chancellor of the Exchequer, how many promoters and operators of schemes now subject to the Loan Charge have been prosecuted for promoting and operating these schemes.

Answered by James Murray - Exchequer Secretary (HM Treasury)

The government has commissioned an independent review of the Loan Charge to help bring the matter to a close for those affected whilst ensuring fairness for all taxpayers.

The Government is committed to tackling promoters of tax avoidance and will consult on measures to tackle promoters of marketed tax avoidance, including new powers focused on those who own or control promoter organisations and options to tackle legal professionals behind avoidance schemes.

The Government announced action at 2024 Autumn Budget to tackle tax avoidance by umbrella companies. Legislation, effective from April 2026, will be introduced 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. This along with the measures on promoters will help prevent disguised remuneration in the future.

In relation to the prosecution of Loan Charge scheme promoters and operators, I refer the hon. Member for Bury North to the answer I gave on 16 October 2024 to Question UIN 7747.