HMRC will contact all taxpayers affected by the loan charge by mid-March 2025. These letters will inform recipients if their disguised remuneration (DR) schemes are likely to be covered by the ongoing McCann review.
This will be the only communication from HMRC regarding the loan charge until the review concludes, except in cases of statutory or litigation deadlines.
For those with multiple DR schemes, including some outside the review’s scope, HMRC will allow delays in progressing their cases. Taxpayers can request a pause on discussions until the review is complete. If the arrangements fall outside the review’s remit, HMRC will not issue assessments or close enquiries unless necessary to meet legal deadlines.
Each letter will include:
- Confirmation of whether HMRC believes the taxpayer’s DR schemes are within the review’s scope.
- A named HMRC contact.
- An explanation of the next steps.
HMRC advises taxpayers to notify their assigned contact if they believe the details in their letter are incorrect.
Taxpayers with finalised tax positions but outstanding payments will receive letters explaining the review’s implications for their agreements.
HMRC acknowledges that uncertainty remains. The online guidance states that taxpayers will only receive full clarity after publishing the review’s findings and the Government’s response. At that point, HMRC will provide further updates.
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