Matt Hall explains the part HMRC had to play in the so-called Loan Charge scandal.
The announcement on 23 January 2025 of the Loan Charge review1 that is not a review of the Loan Charge has once more brought HMRC’s pursuit of what it terms ‘Disguised Remuneration’ (DR) schemes into focus.
The Labour government, like its predecessor, appears to have been persuaded that “those who did not pay the right amount of income tax and National Insurance are required to resolve their affairs with HMRC” as the introduction to the latest review declares. Those hoping for a forensic analysis of how a scandal more than 20 years in the making has evolved will be disappointed. Significantly, this careful control of the narrative omits HMRC’s own part in what many affected call the ‘Loan Charge scandal’. This article therefore explores HMRC’s role.
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