Independent loan charge reviews

Copyright © 2026 LexisNexis
Produced by a Tolley Employment Tax expert
Employment Tax
Guidance

Independent loan charge reviews

Copyright © 2026 LexisNexis
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’ 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

Following on from an earlier review in 2019, a new and independent review into the loan charge was commissioned by HM Treasury in January 2025, and the report was completed in Summer 2025. As part of Autumn Budget 2025, the Government confirmed that all but one of the review’s recommendations were to be accepted. These introduce a number of new calculation measures, access to which, the Government hopes, will bring these long-standing

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  • 19 Jan 2026 10:10

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