Disguised remuneration schemes are contrived arrangements that use loan payments in place of ordinary remuneration, usually through an offshore trust, with the purpose of avoiding tax. These loans are no different to normal income in their purpose and effect, and HMRC’s position is that they are, and have always been, taxable.
In accordance with an amendment to the Finance Act 2019, the Government published a report into disguised remuneration schemes. This can be found online at: www.gov.uk/government/publications/report-on-time-limits-and-the-disguised-remuneration-loan-charge. The Government has no plans to review the policy.
HMRC offers a range of taxpayer support services, both directly and through independent organisations, and would strongly encourage anyone who is affected by the charge to contact them and discuss their situation.