Joshua Gardner

After months of delay, HMRC’s new Loan Charge Settlement Scheme is finally in force. The Employment and Trading Income etc. (Loan Charge Settlement Scheme) Regulations 2026 came into force on **5 August 2026**, following the publication of HMRC’s detailed guidance on 17 July. For individuals and employers who have spent years trying to resolve disguised remuneration liabilities, there is now a formal route to settlement under the revised terms announced following Ray McCann’s review.

HMRC’s revised settlement terms for disguised remuneration cases remain unpublished, despite earlier indications that they would be released in the spring. For affected taxpayers and advisers, the continuing delay is frustrating and prolongs uncertainty in an area already marked by significant financial and personal strain. This update considers why revised, workable settlement terms are urgently needed, the unresolved issues arising from HMRC’s 2020 settlement approach, and the hope that the eventual guidance will provide a clearer and more pragmatic route to resolution.

HMRC can issue information notices to UK taxpayers outside the UK, but the practical risks often lie less in the validity of the notice and more in how the enquiry develops.