Independent loan charge reviews

Produced by a Tolley Employment Tax expert
Employment Tax
Guidance

Independent loan charge reviews

Produced by a Tolley Employment Tax expert
Employment Tax
Guidance
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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.

2025 further loan charge review

The 2025 review has since resulted in the introduction into legislation of the loan charge settlement scheme. The scheme is effective from 5 August 2026 and applies to outstanding loan charge liabilities, including those that are subject to a previous settlement reached with HMRC at any time on or after 1 June 2021. The scheme incorporated most of the recommendations from the review. See the Loan charge guidance note for further

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