The ‘loan charge’ is a liability which attached to loans made to employees and directors via certain so called ‘disguised remuneration’ (DR) schemes. Liabilities which HMRC argued were due but remained unpaid at 5 April 2019 were identified as definitive liabilities by virtue of a new ‘loan charge’ legislation. See the Loan charge guidance note for further details.

However, the loan charge legislation was considered by many as unfair and, at best, something of a blunt force tool. This has led to two separate independent reviews of the loan charge, details of which are the subject of this guidance note.