The charge on disguised remuneration (DR) loans is targeted at artificial tax avoidance schemes where earnings were paid in the form of loans, often made by an offshore third party. These loans are not repaid in practice and so are no different to ordinary income and are, and always have been, taxable.
It is unfair to ordinary taxpayers to let anybody continue to benefit from contrived tax avoidance of this sort, and that is why this government has taken action to ensure that everybody pays the taxes they owe. The charge, announced at Budget 2016, will arise on 5 April 2019. By then affected users will have had three years to organise their financial affairs.
The Government recognises the charge on DR loans will have a significant impact on some individuals who have used DR schemes, particularly those who used them to avoid the most tax.
HM Revenue and Customs (HMRC) are working to help people put things right. HMRC have published a simplified process for DR scheme users to spread payment of the tax they owe over 5 years if their current income is less than £50,000, and they are no longer in avoidance. Those with higher incomes or who need to pay over a longer period can also request extended payment periods, which will be tailored to individual circumstances. Anyone who is worried about being able to pay what they owe should contact HMRC as soon as possible.