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1718757

registered interest
date	16/05/2024
answering body	Treasury
answering dept id	14
answering dept short name	Treasury
answering dept sort name	Treasury
hansard heading	Tax Avoidance
house id	1
legislature	25259 pref label House of Commons
question text	To ask the Chancellor of the Exchequer, if he will make an estimate of the number of people who will need to sell their home to pay the loan charge.
tabling member constituency	Putney
tabling member printed	Fleur Anderson
uin	26770
answer	answer is ministerial correction date of answer 22/05/2024 answer text <p>HMRC will not force anyone to sell their main home or access their pension funds early to pay their Loan Charge or disguised remuneration debts.</p><p>Anyone who is concerned about their ability to pay what they owe should contact HMRC as soon as possible. HMRC can agree an affordable and sustainable instalment plan based on taxpayers’ specific circumstances and for as long as they need. HMRC can also refer taxpayers for free debt advice that is independent from HMRC.</p> answering member constituency Mid Worcestershire answering member printed Nigel Huddleston question first answered 22/05/2024 13:58:50 answering member 4407 label Biography information for Nigel Huddleston
tabling member	4788 label Biography information for Fleur Anderson

1698108

registered interest
date	22/03/2024
answering body	Treasury
answering dept id	14
answering dept short name	Treasury
answering dept sort name	Treasury
hansard heading	Tax Avoidance
house id	1
legislature	25259 pref label House of Commons
question text	To ask the Chancellor of the Exchequer, pursuant to the Answer of 21 March 2024 to Question 19192 on Tax Avoidance, whether it is his Department's policy to cease recovery of any liabilities incurred before December 2010 in cases where a taxpayer has not received an update for a period of 12 months or more from the initial date of an open enquiry or assessment.
tabling member constituency	St Albans
tabling member printed	Daisy Cooper
uin	20111
answer	answer is ministerial correction date of answer 28/03/2024 answer text <p>In the 2019 Independent Loan Charge Review, Lord Morse recommended that the Loan Charge should only apply to loans made on or after 9 December 2010. The Government accepted this recommendation.</p><p> </p><p>Lord Morse was also clear that, for years before this date, where there is an open enquiry or assessment under appeal, HM Revenue and Customs (HMRC) should still have the ability to pursue the tax due under the existing rules. HMRC has proceeded on this basis and it is its policy to collect tax where it has the ability to do so.</p><p> </p><p>As part of its overall compliance processes and its commitment to update taxpayers at least annually, all of these taxpayers should have received correspondence from HMRC in the last 12 months.</p><p> </p><p>When HMRC opens an enquiry, the information sheet provided includes information about a taxpayer’s right to apply to the First Tier Tribunal for the enquiry to be closed. One of the grounds for making such an application is where there has been an excessive delay during which a taxpayer has not received any communication from HMRC.</p> answering member constituency Mid Worcestershire answering member printed Nigel Huddleston question first answered 28/03/2024 13:40:28 answering member 4407 label Biography information for Nigel Huddleston
tabling member	4769 label Biography information for Daisy Cooper

1696817

registered interest
date	18/03/2024
answering body	Treasury
answering dept id	14
answering dept short name	Treasury
answering dept sort name	Treasury
hansard heading	Tax Avoidance
house id	1
legislature	25259 pref label House of Commons
question text	To ask the Chancellor of the Exchequer, pursuant to the Answer of 12 March 2024 to Question 17136 on Tax Avoidance, whether it is HMRC’s policy to seek to recover tax due for liabilities incurred before December 2010, where a taxpayer has not received correspondence relating to an open compliance check for longer than 12 months.
tabling member constituency	St Albans
tabling member printed	Daisy Cooper
uin	19192
answer	answer is ministerial correction date of answer 21/03/2024 answer text <p>In the 2019 Independent Loan Charge Review, Lord Morse recommended that the Loan Charge should only apply to loans made on or after 9 December 2010. The Government accepted this recommendation.</p><p>However, Lord Morse was also clear that, for years before this date, where there is an open enquiry or assessment under appeal HM Revenue and Customs (HMRC) should still have the ability to pursue the tax due under the existing rules. HMRC has proceeded on this basis.</p><p>HMRC continues to work with and support taxpayers to resolve all outstanding enquiries and assessments relating to their use of disguised remuneration (DR) loans, in accordance with their published DR settlement terms and HMRC’s Litigation and Settlement Strategy</p><p><br>As part of its overall compliance processes and its commitment to update taxpayers at least annually, all of these taxpayers should have received correspondence from HMRC in the last 12 months.</p> answering member constituency Mid Worcestershire answering member printed Nigel Huddleston question first answered 21/03/2024 16:39:29 answering member 4407 label Biography information for Nigel Huddleston
tabling member	4769 label Biography information for Daisy Cooper

1696822

registered interest
date	18/03/2024
answering body	Treasury
answering dept id	14
answering dept short name	Treasury
answering dept sort name	Treasury
hansard heading	Tax Avoidance
house id	1
legislature	25259 pref label House of Commons
question text	To ask the Chancellor of the Exchequer, what recent estimate he has made of the amount and proportion of tax identified by HMRC as being avoided through disguised remuneration schemes that will be paid by people who (a) recommended, (b) promoted and (c) operated such schemes in each of the next five years.
tabling member constituency	Portsmouth South
tabling member printed	Stephen Morgan
uin	19163
answer	answer is ministerial correction date of answer 21/03/2024 answer text <p>I refer the hon. Member for Portsmouth South to the answer given on 20 March to Question <a href="https://questions-statements.parliament.uk/written-questions/detail/2024-03-12/18112" target="_blank">UIN 18112</a></p> answering member constituency Mid Worcestershire answering member printed Nigel Huddleston question first answered 21/03/2024 16:41:24 answering member 4407 label Biography information for Nigel Huddleston
tabling member	4653 label Biography information for Stephen Morgan

1695372

registered interest
date	12/03/2024
answering body	Treasury
answering dept id	14
answering dept short name	Treasury
answering dept sort name	Treasury
hansard heading	Tax Avoidance
house id	1
legislature	25259 pref label House of Commons
question text	To ask the Chancellor of the Exchequer, how much of the tax HMRC identified through disguised remuneration schemes was paid by those who (a) recommended, (b) promoted and (c) operated these schemes in each of the last five years.
tabling member constituency	Hendon
tabling member printed	Dr Matthew Offord
uin	18112
answer	answer is ministerial correction date of answer 19/03/2024 answer text <p>HM Revenue and Customs (HMRC) has taken action to tackle the promoters of avoidance schemes, implementing a wide range of actions to disrupt their activities and supply chains, including publishing the details of promoters.</p><p>However, liability for the tax is always that of the individual and there is no legal mechanism to transfer disguised remuneration liabilities from the scheme users to the promoters.</p><p>As of 29 February 2024, HMRC has published the details of 70 tax avoidance schemes, 65 promoters and 29 connected persons, such as company directors and those individuals in control of the promoting entity.</p><p>HMRC has also issued over 20 stop notices to promoters and published details of 16 of these arrangements. Publishing this information supports taxpayers in identifying tax avoidance schemes so they can steer clear of or exit them.</p><p>The list of details of tax avoidance schemes, promoters, connected persons and stop notices currently published online can be found at:</p><p>https://www.gov.uk/government/publications/named-tax-avoidance-schemes-promoters-enablers-and-suppliers</p> answering member constituency Hitchin and Harpenden answering member printed Bim Afolami question first answered 19/03/2024 16:42:57 answering member 4639 label Biography information for Bim Afolami
tabling member	4006 label Biography information for Dr Matthew Offord

1693906

registered interest
date	05/03/2024
answering body	Treasury
answering dept id	14
answering dept short name	Treasury
answering dept sort name	Treasury
hansard heading	Tax Avoidance
house id	1
legislature	25259 pref label House of Commons
question text	To ask the Chancellor of the Exchequer, how many section 684 notices were issued by HMRC in each of the last five years.
tabling member constituency	East Antrim
tabling member printed	Sammy Wilson
uin	17135
answer	answer is ministerial correction date of answer 12/03/2024 answer text <p>In the context of Disguised Remuneration (DR), HM Revenue and Customs (HMRC) has in some circumstances used the power provided under s.684(7A)(b) of the Income Tax (Earnings and Pensions) Act 2003 (the Discretion) to collect the tax owed; and since 2022, HMRC has issued around 2,700 decisions using the Discretion.</p><p>In his independent review, Lord Morse recommended that the Loan Charge should no longer apply to loans made before 9 December 2010. However, Lord Morse said “HMRC should continue being able to settle and investigate cases prior to this point under their normal powers where they have appropriate grounds, and a legal basis, to do so”.</p><p>In line with this recommendation, HMRC is still seeking to recover the tax due where it had taken the necessary steps in the past to ensure there is an open tax enquiry or assessment which gives it the legal basis to do so.</p><p>In May 2022, the Court of Appeal said that HMRC could consider using the Discretion to collect tax directly from the individual who received income through a DR scheme.</p> answering member constituency Mid Worcestershire answering member printed Nigel Huddleston grouped question UIN 17136 question first answered 12/03/2024 12:57:52 answering member 4407 label Biography information for Nigel Huddleston
tabling member	1593 label Biography information for Sammy Wilson

1693907

registered interest
date	05/03/2024
answering body	Treasury
answering dept id	14
answering dept short name	Treasury
answering dept sort name	Treasury
hansard heading	Tax Avoidance
house id	1
legislature	25259 pref label House of Commons
question text	To ask the Chancellor of the Exchequer, how many notices under section 684 of the Income Tax Act 2007 have been issued to individuals with Loan Charge liabilities incurred before December 2010.
tabling member constituency	East Antrim
tabling member printed	Sammy Wilson
uin	17136
answer	answer is ministerial correction date of answer 12/03/2024 answer text <p>In the context of Disguised Remuneration (DR), HM Revenue and Customs (HMRC) has in some circumstances used the power provided under s.684(7A)(b) of the Income Tax (Earnings and Pensions) Act 2003 (the Discretion) to collect the tax owed; and since 2022, HMRC has issued around 2,700 decisions using the Discretion.</p><p>In his independent review, Lord Morse recommended that the Loan Charge should no longer apply to loans made before 9 December 2010. However, Lord Morse said “HMRC should continue being able to settle and investigate cases prior to this point under their normal powers where they have appropriate grounds, and a legal basis, to do so”.</p><p>In line with this recommendation, HMRC is still seeking to recover the tax due where it had taken the necessary steps in the past to ensure there is an open tax enquiry or assessment which gives it the legal basis to do so.</p><p>In May 2022, the Court of Appeal said that HMRC could consider using the Discretion to collect tax directly from the individual who received income through a DR scheme.</p> answering member constituency Mid Worcestershire answering member printed Nigel Huddleston grouped question UIN 17135 question first answered 12/03/2024 12:57:51 answering member 4407 label Biography information for Nigel Huddleston
tabling member	1593 label Biography information for Sammy Wilson

1692227

registered interest
date	27/02/2024
answering body	Treasury
answering dept id	14
answering dept short name	Treasury
answering dept sort name	Treasury
hansard heading	Tax Avoidance
house id	1
legislature	25259 pref label House of Commons
question text	To ask the Chancellor of the Exchequer, what estimate he has made of the number of people who have been affected by the loan charge.
tabling member constituency	Lewisham East
tabling member printed	Janet Daby
uin	16022
answer	answer is ministerial correction date of answer 04/03/2024 answer text <p>In September 2023, HM Revenue and Customs published an updated issue briefing on disguised remuneration and the loan charge. The issue briefing contains information at UK level and is available on GOV.UK here:</p><p><a href="https://www.gov.uk/government/publications/hmrc-issue-briefing-disguised-remuneration-charge-on-loans/hmrc-issue-briefing-settling-disguised-remuneration-scheme-use-andor-paying-the-loan-charge#customers-subject-to-the-loan-charge" target="_blank">https://www.gov.uk/government/publications/hmrc-issue-briefing-disguised-remuneration-charge-on-loans/hmrc-issue-briefing-settling-disguised-remuneration-scheme-use-andor-paying-the-loan-charge#customers-subject-to-the-loan-charge</a></p> answering member constituency Mid Worcestershire answering member printed Nigel Huddleston question first answered 04/03/2024 15:19:05 answering member 4407 label Biography information for Nigel Huddleston
tabling member	4698 label Biography information for Janet Daby

1691630

registered interest
date	26/02/2024
answering body	Treasury
answering dept id	14
answering dept short name	Treasury
answering dept sort name	Treasury
hansard heading	Tax Avoidance
house id	1
legislature	25259 pref label House of Commons
question text	To ask the Chancellor of the Exchequer, whether his Department has made an assessment of the potential merits of publishing the written responses to its consultation entitled Tackling disguised remuneration, which closed on 5 October 2016.
tabling member constituency	Inverness, Nairn, Badenoch and Strathspey
tabling member printed	Drew Hendry
uin	15681
answer	answer is ministerial correction date of answer 01/03/2024 answer text <p>The Government published a technical note and summary of responses to the Tackling Disguised Remuneration consultation on 5 December 2016: <a href="https://assets.publishing.service.gov.uk/media/5d2891ffed915d2ff003b6d0/Tackling_disguised_remuneration_-_Technical_note_and_summary_of_responses_amended.pdf" target="_blank">Tackling disguised remuneration. Technical note and summary of responses</a></p><p> </p><p>The Government does not routinely publish individual consultation responses.</p> answering member constituency Mid Worcestershire answering member printed Nigel Huddleston question first answered 01/03/2024 09:26:10 answering member 4407 label Biography information for Nigel Huddleston
tabling member	4467 label Biography information for Drew Hendry

1686477

registered interest
date	31/01/2024
answering body	Treasury
answering dept id	14
answering dept short name	Treasury
answering dept sort name	Treasury
hansard heading	Tax Avoidance
house id	1
legislature	25259 pref label House of Commons
question text	To ask the Chancellor of the Exchequer, if he will make it his policy to recover tax avoided through disguised remuneration tax avoidance schemes from people who (a) recommended, (b) promoted and (c) operated those schemes.
tabling member constituency	North East Hampshire
tabling member printed	Mr Ranil Jayawardena
uin	12465
answer	answer is ministerial correction date of answer 08/02/2024 answer text <p>HMRC has taken action to tackle the promoters of avoidance schemes, implementing a wide range of actions to disrupt their activities and supply chains, including publishing the details of promoters.</p><p> </p><p>However, liability for the tax is always that of the individual and there is no legal mechanism to transfer disguised remuneration liabilities from the scheme users to the promoters.</p><p> </p><p>As of 31 December, HMRC has published the details of 59 promoters, 23 directors and details of 64 tax avoidance schemes.</p><p>HMRC has also issued over 20 stop notices to promoters and published details of 16 of these arrangements. Publishing this information supports taxpayers in identifying tax avoidance schemes so they can steer clear of or exit them.</p><p> </p><p>The current Finance Bill is introducing tougher consequences for promoters of tax avoidance. This includes a new criminal offence to strengthen the deterrent to promoting tax avoidance, making it clear promoters must stop promoting these schemes, and a power enabling HMRC to act more quickly to disqualify directors of companies involved in tax avoidance.</p> answering member constituency Mid Worcestershire answering member printed Nigel Huddleston question first answered 08/02/2024 12:59:47 answering member 4407 label Biography information for Nigel Huddleston
tabling member	4498 label Biography information for Mr Ranil Jayawardena