Can’t get no Satisfaction by Matt Hill

Disguised Remuneration schemes? More like disguised ‘customer’ service, says Matt Hall.


Since its inception Armadillo has dealt with hundreds of individuals caught up in what HMRC term ‘Disguised Remuneration’ (DR) schemes. The introduction of the ‘loan charge’, defeats in Court and increasing interest rates mean that the majority taxpayers involved in these types of arrangements have tried to settle their affairs with HMRC.


Hundreds of our clients were able to do so before HMRC’s self-imposed deadline of 30 September 2020. Many were not. Anyone familiar with that settlement process will recognise innumerable and significant HMRC delays (measured in months, not weeks), error and often absurd interpretations of what was affordable.

“We are sorry for the delay in replying to your letter of……..” was and remains a templated opening to the vast majority of HMRC issued correspondence. It is the hollowest of apologies.

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