HMRC say that where a settlement has not been reached on a disguised remuneration loan scheme by 5 April 2019, they will still give consideration to reaching an agreement under the existing terms.

On 6 April 2019 a loan charge applies to all Disguised Remuneration loans outstanding on 5 April 2019, unless a settlement agreement has been reached before that date.

The original deadline for registering for settlement was 31 May 2018 however HMRC have continued to allow taxpayers to register.

HMRC now say that they will consider whether or not to extend settlement under the existing terms beyond 5 April.

  • Each case will be considered individually, and, when deciding whether to allow the taxpayer to settle post 5 April, HMRC will look at whether the taxpayer has met all of HMRC’s deadlines and if they have responded promptly to queries and correspondence. 
  • If a taxpayer has not been able to settle by 5 April solely due error or delay by HMRC, HMRC will ensure that the taxpayer is not disadvantaged as a result.


If you have an unsettled disguised remuneration loan/contractor loan/EBT loan etc still outstanding it is essential to have made contact HMRC if you still wish to settle.

Useful guides:

FAQs for Disguised Remuneration Settlement
This guide looks at Frequently Asked Questions for settling Disguised Remuneration schemes. The FAQs relate to EBTs, EFRBS and contractor loan schemes (employed and self-employed).

Disguised Remuneration final settlement opportunity
A detailed guide to the November 2017 final settlement opportunity for all disguised remuneration schemes.