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Re:

HMRC’s Loan Charge Settlement Pause: What Changed After the Independent Review

The reported Loan Charge pause was request-based, not universal. The review has concluded; HMRC says case reviews and letters began in January 2026, while legislation was still ongoing in the latest official update cited here.
From TheFinanceBase Team4 min to read
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The November 2024 report that HMRC was pausing some Loan Charge settlement activity described a limited, request-based arrangement—not a blanket halt. That interim period has ended: the independent review concluded in 2025, and HMRC says it began reviewing cases and sending letters in January 2026. The new settlement opportunity was still awaiting legislation in the latest official update retrieved here, dated 29 June 2026.

What did “on pause by request” mean?

On 14 November 2024, Computer Weekly reported that HMRC was accepting individual customer requests to pause current Loan Charge settlement activity while a planned independent review was pending. The report quoted an HMRC email saying the department had “not yet been instructed to” pause settlements generally, but had “been asked to accept customer requests to pause current settlement activity.”

That account did not establish a blanket suspension, a universal entitlement to a pause, or that all HMRC activity connected with disguised remuneration arrangements had stopped. If you are dealing with HMRC now, do not assume the 2024 arrangement remains available: refer to your current correspondence and ask your HMRC contact about your own case.

What happened to the independent review?

The government commissioned a new review in January 2025, led by Ray McCann, a former President of the Chartered Institute of Taxation. HM Treasury published the final report and the government response in November 2025. The government accepted the review’s main recommendation: a new settlement opportunity for outstanding Loan Charge liabilities. See HM Treasury’s Loan Charge review collection for the report and response.

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The review’s conclusion means the 2024 “until the review concludes” wording is historical, not a description of the current pause status. The review’s recommendation and the government’s acceptance also do not, by themselves, mean every person with a Loan Charge-related arrangement qualifies for the new terms.

What is HMRC doing now?

Case reviews and letters

HMRC’s operational guidance, published 9 February 2026, says: “HMRC (HM Revenue and Customs) has now started reviewing customers’ arrangements and started sending out letters in January 2026.” HMRC says contact will be staged and tailored to each customer’s circumstances. Some people who received an early-2025 letter identifying arrangements HMRC believed the review might cover can indicate interest in settling under the new terms. Read the current HMRC guidance on what happens after the 2025 review and follow the instructions in any letter you receive.

Legislation and settlement terms

As of the latest official status in the material available here, the new opportunity was not yet confirmed as in force. HMRC’s 9 February 2026 technical note describes its implementation as provisional pending legislation and definitive regulations. A UK Parliament written answer on 29 June 2026 said legislation was ongoing; it is available through the parliamentary answer. Check current HMRC guidance and legislation before relying on this status, because later enactment or regulations may have changed it.

HMRC says customers whose arrangements are covered by recommendations accepted by the government should later receive an invitation to settle at a reduced amount. Eligibility and terms depend on the individual case; the sources do not establish one reduced figure or a timetable that applies to everyone.

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What should you do if you may be affected?

  1. Read your latest HMRC letter. Check whether HMRC has contacted you about a review of your arrangement or an opportunity to express interest in the new terms. Respond using the method and deadline stated in the letter.
  2. Ask HMRC about your own case. If you have an active settlement discussion, use the contact details on your correspondence to ask what applies now. Do not treat the November 2024 request-based pause as a current general right.
  3. Consider independent, qualified advice where your circumstances warrant it. HMRC’s technical note says customers may want advice on whether inheritance tax could apply and whether trust arrangements need to be wound up as part of settlement. Those are issues to assess individually, not evidence that inheritance tax is due in every case.
  4. Keep the Loan Charge opportunity separate from other enquiries. HMRC’s issue briefing says disguised remuneration schemes outside the Loan Charge’s scope may still be subject to tax enquiries and settlement. A possible future settlement opportunity does not mean other HMRC matters have ended.

How to read the older Loan Charge figures

Published figures refer to different dates and measures. They should not be treated as a current count of affected people or as results from the new settlement opportunity.

Figure What it measures
Up to £3.4 billion over five years HMRC’s potential receipts estimate, as reported by Computer Weekly on 14 November 2024—not realised receipts. Source.
Approximately 61,000 individuals HMRC’s historical estimate of people expected to be affected before changes following an earlier independent review; the publication date is not stated in the source search result. Source.
Around 20,200 settlements and around £3.4 billion brought into charge HMRC’s cumulative historical figures through the end of March 2022—not a forecast or a result of the new opportunity. Source.
Around 1,300 people HMRC’s 2020 implementation report said this many people still eligible to settle after the earlier review were no longer liable for the Loan Charge. Source.
5,600 employers and individuals HMRC’s 2020 implementation report said this many had settled by 30 September 2020. Source.

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