Disguised remuneration and the self-employed

Copyright © 2025 LexisNexis
Produced in partnership with Stephen Downie of Francis Wilks & Jones
Practice notes

Disguised remuneration and the self-employed

Copyright © 2025 LexisNexis

Produced in partnership with Stephen Downie of Francis Wilks & Jones

Practice notes
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FORTHCOMING CHANGE: As announced at Autumn Budget 2024, the government has commissioned an independent review of the loan charge. The review, announced on 23 January 2025, will ‘examine the barriers preventing those who are subject to the loan charge but have not already settled and paid their tax liabilities in full from reaching resolution with HMRC’ and will ‘recommend ways in which they can be encouraged to settle with HMRC’. To assist with the review, a call for evidence, aimed at those who remain subject to the loan charge (and their advisers), was published on 28 March 2025. The outcome of the review, with recommendations, will be reported and presented to the Exchequer Secretary to the Treasury ‘by Summer 2025’. For more on the review, see News Analysis: Autumn Budget 2024—Independent review of the loan charge. HMRC has confirmed the operational activity it will undertake while the independent review is ongoing. This includes sending letters (and a Q&A document) to affected taxpayers setting out whether HMRC believes the disguised Remuneration

Stephen Downie
Stephen Downie

Solicitor, Francis Wilks & Jones

Stephen is a dual qualified solicitor and ACCA accountant, and is a partner at Francis Wilks & Jones acting for tax advisors, private clients and Insolvency Practitioners.

Stephen works with FWJ’s tax disputes team dealing with Code 8 and Code 9 enquiries, direct and indirect tax investigations and tribunal proceedings; Stephen’s particular specialism in this area comprises the evolving legal position surrounding tax avoidance schemes in respect of both live and insolvent companies.

Stephen’s person experience over the course of the last 20 years also extends to insolvency, restructuring and contentious insolvency claims, acting on both sides for both liquidators/administrators and defending SMEs, individuals and directors.

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Jurisdiction(s):
United Kingdom
Related legal acts:
Key definition:
Remuneration definition
What does Remuneration mean?

In a defined benefit scheme, the amount of pension earned is invariably related to the amount of salary; HMRC calls this remuneration. So far as scheme rules or an employer's policy is concerned, it can include or exclude bonuses, commission and other fluctuating emoluments.

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