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The Government released on 20 December 2019 a copy of the loan charge independent review report, containing some considerable changes to the loan charge.

The review, led by Sir Amyas Morse, was commissioned to look at the impact of the charge, which was introduced to tackle what the Treasury described as ‘disguised remuneration schemes’.

For a brief history of the loan charge, see the Loan charge guidance note and ‘Morse Code’ by David Graham in Taxation, 16 January 2020, 11.

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 HMRC. See the Written Ministerial Statement. See also HMRC issue briefing: operational activity during the new independent review of the Loan Charge.

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