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S9 Enquiries on returns
Source: WhatDoTheyKnow
Authority: HM Revenue and Customs
Status: Response to this request is
long overdue
. By law, under all circumstances,
HM Revenue and Customs
should have responded by now (
details
). The person who made the request can
complain
by
requesting an internal review
.
Imported path: /opt/loancharge/imports/wdtk/requests/s9_enquiries_on_returns
Open original request on WhatDoTheyKnow
Imported text
SOURCE: WhatDoTheyKnow
SOURCE_URL: https://www.whatdotheyknow.com/request/s9_enquiries_on_returns
TITLE: S9 Enquiries on returns
AUTHORITY: HM Revenue and Customs
AUTHORITY_URL: https://www.whatdotheyknow.com/body/hmrc
STATUS: Response to this request is
long overdue
. By law, under all circumstances,
HM Revenue and Customs
should have responded by now (
details
). The person who made the request can
complain
by
requesting an internal review
.
REQUEST_SLUG: s9_enquiries_on_returns
CAPTURED_AT: 2026-05-19T07:04:17+00:00
PROVENANCE: {"first_seen_at": "2026-05-18T12:54:22", "first_seen_page": "5", "first_query_term": "\"Loan Charge\"", "first_date_after": "2021/01/01", "first_date_before": "2022/01/01", "matched_query_terms": "\"Loan Charge\" | \"disguised remuneration\"", "matched_date_ranges": "2021/01/01 to 2022/01/01", "first_search_url_template": "https://www.whatdotheyknow.com/search/%22Loan%20Charge%22/requests?commit=Filter&query=%22Loan+Charge%22&request_date_after=2021%2F01%2F01&request_date_before=2022%2F01%2F01&request_variety%5B%5D=sent&request_variety%5B%5D=response&request_variety%5B%5D=comment&sortby=&utf8=%E2%9C%93&page="}
ATTACHMENTS:
- 20210414_response.pdf | https://www.whatdotheyknow.com/request/s9_enquiries_on_returns/response/1768705/attach/3/20210414%20response.pdf?cookie_passthrough=1 | application/pdf | 121717 bytes
- [not downloaded] | https://www.whatdotheyknow.com/request/s9_enquiries_on_returns/response/1768705/attach/html/3/20210414%20response.pdf.html | | 0 bytes
================================================================================
MESSAGE 1 [outgoing]
HEADER: Jeff Bradshaw
18 March 2021
Delivered
--------------------------------------------------------------------------------
Dear HM Revenue and Customs,
I would like to know how many section 9A enquiries have been opened as a result of the disguised renumeration section in the 2018/19 tax return. Including those opened as a result of the returns submitted by 30th September 2020.
I would also like to know what percentage is this of tax returns where the disguised renumeration portions of the tax return were completed.
Yours faithfully,
Jeff Bradshaw
================================================================================
MESSAGE 2 [incoming]
HEADER: FOI Central Team,
HM Revenue and Customs
19 March 2021
--------------------------------------------------------------------------------
Our ref: FOI2021/04967
Dear Mr Bradshaw,
Freedom of Information Act 2000 Acknowledgement
Thank you for your communication of 18th March which has been passed to
HMRC's Freedom of Information Team.
We have allocated the above reference which you should quote if you need
to contact us.
The Team will arrange for a reply to be sent to you which will either
comply with HMRC's obligations under Freedom of Information Act or, if we
think it's an enquiry that we don't need to address under the terms of the
Act, let you know why. If it is the latter we will, if possible, pass it
on to a more appropriate part of the Department f or answer.
As you will appreciate, the coronavirus pandemic has provided
unprecedented challenges for Government Departments including HMRC. Over
the coming weeks our priorities are to provide critical existing and new
Public Services for Government to support customers during this difficult
time. As a result, resources may be diverted away from usual compliance or
information rights work. HMRC aims to respond to all FOIA Requests within
20 working days. If for whatever reason this timescale cannot be complied
with HMRC will, where possible, write to you explaining the reason for the
delay and providing an estimated time for response.
Yours sincerely
HMRC Freedom of Information Act Team
================================================================================
MESSAGE 3 [incoming]
HEADER: FOI Central Team,
HM Revenue and Customs
14 April 2021
--------------------------------------------------------------------------------
1 Attachment
20210414 response.pdf
118K
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Dear Mr Bradshaw
We are writing in response to your request for information, received on 18
March 2021.
Yours sincerely,
HMRC Freedom of Information Team
================================================================================
ATTACHMENT TEXT EXTRACTION / OCR
================================================================================
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ATTACHMENT: 20210414_response.pdf
TEXT_FILE: 20210414_response.pdf.txt
METHOD: pdf_native
OCR_USED: False
PAGES: 1
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--- PDF page 1 ---
Information is available in large print, audio and Braille formats.
Text Relay service prefix number – 18001
OFFICIAL
Freedom of Information Team
S1715
6 Floor
Central Mail Unit
Newcastle Upon Tyne
NE98 1ZZ
Mr Jeff Bradshaw
By email:
request-737812-5ab97bc3@whatdotheyknow.com
Email
foi.request@hmrc.gov.uk
Web
www.gov.uk
Date: 14 April 2021
Our ref:
FOI2021/04967
Dear Mr Bradshaw
Freedom of Information Act 2000 (FOIA)
Thank you for your request, which was received on 18 March, for the following information:
“I would like to know how many section 9A enquiries have been opened as a result of the
disguised renumeration section in the 2018/19 tax return. Including those opened as a result
of the returns submitted by 30th September 2020.
I would also like to know what percentage is this of tax returns where the disguised
renumeration portions of the tax return were completed.”
We can confirm that we have to date opened over 1,900 section 9A enquiries into 2018-19
tax returns where the disguised remuneration section of the return was completed. This is
approximately 30% of these tax returns.
Following the December 2019 conclusion of the Independent Loan Charge review,
customers affected had until the 30 September 2020 to file and pay the Loan Charge or
agree a Time to Pay arrangement. We continue to review the submitted returns and
continue to undertake a range of compliance activity on them. The time limit for us to open
an enquiry into a tax return is 12 months from the date that the return was filed, which
means that we will need to make enquiries by 30 September 2021 into tax returns filed by 30
September 2020. Further information about our enquiries into tax returns is available at:
www.gov.uk/hmrc-internal-manuals/self-assessment-legal-framework/salf403
If you are not satisfied with this reply you may request a review within two months by
emailing foi.review@hmrc.gov.uk, or by writing to the address at the top right-hand side of
this letter.
If you are not content with the outcome of an internal review you can complain to the
Information Commissioner’s Office.
Yours sincerely,
HM Revenue and Customs