HMRC to Contact All Taxpayers Affected by Loan Charge by Mid-March

What's happening with the Loan Charge in 2025?

HMRC has announced plans to write to all taxpayers impacted by the loan charge by mid-March 2025. These letters will inform recipients whether their disguised remuneration (DR) scheme falls within the scope of the ongoing McCann review.

This will be the sole communication between HMRC and affected taxpayers until the review is completed. For taxpayers involved in multiple DR arrangements, including those outside the scope of the review, it appears that discussions with HMRC may be deferred.

According to HMRC’s briefing: “Customers who would prefer to wait and finalise their tax positions for all their DR arrangements at the same time, can ask HMRC to pause this work until the review is complete.

“Where a pause is requested for arrangements that will not be considered by the review, HMRC will not issue assessments nor close any enquiries to finalise the amounts due for these arrangements, unless there are important matters such as statutory or litigation deadlines we need to meet.”

HMRC also confirmed that during the review, affected customers whose arrangements fall within the scope of the review will not be contacted further unless necessary. Exceptions include situations involving litigation deadlines or instances where customers indicate they wish to proceed with their case.

The operational update follows the Treasury’s decision to initiate a limited-scope independent review of the loan charge, led by tax expert Ray McCann.

Key details of the HMRC communication

HMRC’s first step will be to send letters to taxpayers with outstanding tax bills related to DR arrangements. According to the agency, all affected taxpayers will receive these letters by mid-March 2025.

Each letter will include:

• A named HMRC contact for the taxpayer.
• HMRC’s assessment of whether the taxpayer’s DR arrangements fall within the scope of the McCann review.
• Guidance on next steps for the taxpayer.

HMRC emphasized that these letters will be based on the information it currently holds. Taxpayers who believe this information is inaccurate are encouraged to contact the HMRC representative named in their letter.

Remaining Loan Charge uncertainty

The HMRC online update has left some taxpayers concerned due to its ambiguous language. A grey box labeled “Important” in the guidance notes states: “HMRC won’t be able to tell customers exactly how they may be affected until both the review is complete, and the findings are published; and the government issues its response to any review recommendations. HMRC will then write to customers again to update them on next steps.”

Letters for finalised tax positions

In addition to contacting those with outstanding tax positions, HMRC will also write to taxpayers who have finalized their tax arrangements but have yet to fully pay the agreed amount. These letters will explain how the review impacts their current agreements.

Ongoing engagement during the review

While the McCann review is underway, HMRC will continue to work with taxpayers to finalize tax positions for DR arrangements that are not under review. Taxpayers with general questions about disguised remuneration schemes can still contact HMRC’s dedicated phone line at 0300 322 9420.