HMRC have 1,000 officers working to agree a settlement with an estimated 9,000 outstanding Disguised Remuneration cases before the settlement deadline of 30 September 2020. Of the 9,000 taxpayers, around 3,000 have not responded to HMRC and so it may be tricky for them to settle. A further 6,000 cases are unsettled and those taxpayers will become subject to the Loan Charge.

The figures were provided in the evidence presented to the House of Common’s Public Accountants Committee (PAC) during their review of ‘Tackling the tax gap’. 

The Disguised Remuneration Settlement Opportunity runs until 30 September 2020. Taxpayers who fail to settle become subject to the Loan Charge, this applies from April 2019. It is possible to spread the charge across several tax years. 

The PAC discovered that it is not easy to verify the exact numbers as HMRC is uncertain. According to Penny Ciniewicz, Director General, of HMRC’s Customer Compliance Group,

"It was originally estimated that 50,000 individuals were affected by the loan charge. HMRC estimates that around 11,000 were taken out of that by the December ’19 changes following Sir Amyas Morse’s Report, and around 1,000 employers were also removed. At that time, HMRC had around 12,000 customers who still had the opportunity to conclude a settlement. around 2,000 of those have settled or no longer need to settle, for example, because their loans were taken out of the scope of the loan charge. We have around 6,000 customers who are actively in the process of conversation with us and may still settle with us. Another 3,700 or so customers remain out of that 12,000 balance of customers who are still able to settle, and a small number of those have asked us to pause, mainly due to COVID-related issues. Around 3,000 of those customers who were able to settle originally have not responded to our letters or have missed deadlines, so it may be tricky for them to settle with us before 30 September."


Disguised Remuneration Zone
A freeview zone which details the settlement opportunities, details of the loan charge with links to useful materials

Disguised Remuneration Loan Charge
Subscriber guide to the paying and calculating the disguised remuneration loan charge.

External links

House of Commons PAC Evidence 7 Sept 2020