Disguised remuneration and other tax avoidance arrangements

Many UK taxpayers have participated in tax avoidance arrangements, no doubt attracted by the tax savings they expected.  Whilst many such arrangements (often referred to as “schemes” by HMRC) are perfectly legal, the government has long sought to banish them from the UK tax system, or at least make them less attractive.

Disguised remuneration tax avoidance schemes often seek involve a loan or other payment from a third-party as an alternative to the payment of  dividends or bonuses.

A charge on disguised remuneration loans, known as the loan charge, was introduced to tackle the use of disguised remuneration schemes and came into effect on 5 April 2019. The charge applies to loans made after 9 December 2010, if they were still outstanding on 5 April 2019.

Many users of these arrangements have lived with unresolved tax positions for several years and in our experience, the complexities involved in settling their positions with HMRC once and for all has been daunting..  Some users also have concerns regarding how they will be able to pay HMRC what they owe.

HMRC published revised settlement terms in November 2020 and has invited those  who have yet to resolve their tax positions to come forward and settle.  If you are a user of a disguised remuneration arrangement and need reliable, straightforward guidance on how to proceed, we can help.

Perhaps you remain in dispute because HMRC is looking to charge penalties in respect of the arrangements.  Maybe you are concerned about your ability to pay the liabilities arising all at once.  Are there legacy structures which were established for the arrangements which remain in place and are accruing ongoing costs?

If you would like a free consultation to discuss your specific circumstances and how we might help you, please contact us.