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Ray McCann was commissioned to lead an independent review aimed at resolving outstanding UK Loan Charge cases, but he was not free to recommend repeal. In an interview published on 1 April 2025, he said the government had ruled repeal out and that he agreed with that position. The review later made nine recommendations; the government accepted eight and rejected its proposed ten-year maximum for payment plans. HMRC published implementation guidance in September 2026, so that guidance—not the 2025 interview—is the place to check how the settlement scheme operates now.
Who is Ray McCann?
HM Treasury commissioned McCann on 23 January 2025 to lead the independent Loan Charge review. The Treasury said his experience, understanding of the issue and standing across the tax industry were reasons for appointing him. Its launch announcement identified him as a former president of the Chartered Institute of Taxation.
In the Computer Weekly interview, McCann described a long involvement with disguised-remuneration enforcement and said he had publicly criticised HMRC’s approach to settlements. Those details are his account in the interview, rather than the stated basis for the Treasury appointment.
What was the review asked to examine?
The Loan Charge was announced in 2016 and legislated through the Finance (No. 2) Act 2017. It was intended to address historic arrangements that treated remuneration as loans in an effort to avoid income tax and National Insurance.
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The review’s terms covered disguised-remuneration use between 9 December 2010 and 5 April 2019 where it fell within the Loan Charge legislation. Its focus was people who had not already settled and paid their liabilities in full. It covered both outstanding Loan Charge liabilities and related outstanding liabilities on the underlying income; it was not a review of every disguised-remuneration arrangement.
McCann was asked to consider the available settlement terms and HMRC’s debt-management processes in light of people’s ability to pay and their behaviour, ways to encourage people to resolve their cases, and targeted changes that would not create significant extra administrative work for HMRC.
What did McCann say about repeal and independence?
McCann said repeal was not an option open to him, invoking fairness to taxpayers who had paid income tax and National Insurance on their earnings. He put his position plainly: “It’s not open to me to recommend that the Loan Charge be repealed, and the government has made clear from the start that repeal was not an option, and equally I don’t think it should be.”
He also said the government had constrained possible recommendations to the prevailing fiscal situation while leaving him discretion over how to conduct the review. At its launch, he said the controversy had “for too long acted as a barrier to bringing matters to a close for both the individuals involved and for HMRC.”
The process included officials who had not previously worked on the policy area and were based outside Treasury and HMRC offices. McCann had final say over the report’s contents; the terms also anticipated factual comments from the departments and publication of information they supplied after the review. These arrangements describe how the review was conducted, but do not by themselves resolve wider arguments about its independence.
What did the review recommend, and what did the government decide?
McCann’s final report made nine recommendations, with a new settlement opportunity for people with outstanding Loan Charge liabilities as its main proposal. The government accepted eight recommendations and rejected the proposed ten-year maximum for payment plans. Instead, it said HMRC would consider longer arrangements where needed.
The government response also went further than the report in some respects: under the new settlement, amounts would be written off rather than suspended, and employers could access the same settlement terms as employees.
HM Treasury estimated that most individuals could see reductions of at least 50% in outstanding Loan Charge liabilities and that about 30% could have those liabilities written off entirely. It also provided a £5,000 deduction for each person in scope and capped the maximum write-off at £70,000; the government estimated that more than 80% would not be affected by the cap. These are projected effects of the proposed settlement, not evidence of completed outcomes.
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The 2025 review reported HMRC estimates of around 45,000 individuals in scope. Of those, around 12,000 had resolved their scheme use, while around 32,000 had unresolved scheme use and/or outstanding liabilities without a contract settlement. The categories and rounded figures come from HMRC estimates reported in the review; they are not a current count of people still waiting for an offer.
What should affected taxpayers check now?
HMRC published its implementation guide on 7 September 2026. It explains how the settlement scheme is applied, including offer timing, deadlines for taxpayers and employers, calculation of offer amounts and treatment of different customer groups. Because operational details may change, use the current HMRC guide to establish what applies to a particular case rather than relying on McCann’s earlier interview.
The government response says the opportunity is for individuals and employers who have not yet settled and paid outstanding Loan Charge liabilities. Where a case includes both Loan Charge and other disguised-remuneration liabilities, all disguised-remuneration avoidance must be settled to access the opportunity, but only liabilities within the Loan Charge scope receive its concessions. Anyone considering an offer should check their own eligibility, amounts and deadlines against HMRC’s guidance and obtain specialist UK tax advice where needed.
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