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A person (P) is treated as taking a relevant step for the purposes of the disguised remuneration provisions if P has made a loan or quasi-loan to a 'relevant person' on or after 9 December 2010¹ and any part of it remains outstanding immediately before the end of 5 April 2019. The loan charge originally applied to loans and quasi-loans made on or after 6 April 1999² which had outstanding balances immediately before 5 April 2019. Following an independent review of the loan charge in December 2019 (see below) this period has been substantially reduced by the FA 2020.

Note that a further independent review into the loan charge was launched in January 2025. This is due to report in Summer 2025. The review will examine the barriers preventing those who are subject to the loan charge but have not already settled and paid their tax liabilities in full from reaching resolution with HMRC. It will recommend ways in which they can be encouraged to settle with