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"Tackling disguised remuneration" - policy impact assessments
Source: WhatDoTheyKnow
Authority: HM Revenue and Customs
Status: The request was
refused
by
HM Revenue and Customs
.
Imported path: /opt/loancharge/imports/wdtk/requests/tackling_disguised_remuneration
Open original request on WhatDoTheyKnow
Imported text
SOURCE: WhatDoTheyKnow
SOURCE_URL: https://www.whatdotheyknow.com/request/tackling_disguised_remuneration
TITLE: "Tackling disguised remuneration" - policy impact assessments
AUTHORITY: HM Revenue and Customs
AUTHORITY_URL: https://www.whatdotheyknow.com/body/hmrc
STATUS: The request was
refused
by
HM Revenue and Customs
.
REQUEST_SLUG: tackling_disguised_remuneration
CAPTURED_AT: 2026-05-19T07:10:11+00:00
PROVENANCE: {"first_seen_at": "2026-05-18T12:51:54", "first_seen_page": "4", "first_query_term": "\"Loan Charge\"", "first_date_after": "2018/01/01", "first_date_before": "2019/01/01", "matched_query_terms": "\"Loan Charge\" | \"disguised remuneration\"", "matched_date_ranges": "2018/01/01 to 2019/01/01", "first_search_url_template": "https://www.whatdotheyknow.com/search/%22Loan%20Charge%22/requests?commit=Filter&query=%22Loan+Charge%22&request_date_after=2018%2F01%2F01&request_date_before=2019%2F01%2F01&request_variety%5B%5D=sent&request_variety%5B%5D=response&request_variety%5B%5D=comment&sortby=&utf8=%E2%9C%93&page="}
ATTACHMENTS:
- FOI2018_01109_Wright.pdf | https://www.whatdotheyknow.com/request/487899/response/1176411/attach/2/FOI2018%2001109%20Wright.pdf | application/pdf | 151979 bytes
- FOI2018_01301_Robinson.pdf | https://www.whatdotheyknow.com/request/tackling_disguised_remuneration/response/1181686/attach/2/FOI2018%2001301%20Robinson.pdf?cookie_passthrough=1 | application/pdf | 252837 bytes
- [not downloaded] | https://www.whatdotheyknow.com/request/tackling_disguised_remuneration/response/1181686/attach/html/2/FOI2018%2001301%20Robinson.pdf.html | | 0 bytes
================================================================================
MESSAGE 1 [outgoing]
HEADER: Chris Robinson
21 June 2018
Delivered
--------------------------------------------------------------------------------
Dear Sirs,
In an answer dated 14 June 2018 to a FOI request made by Mr Colin Wight (link:
https://www.whatdotheyknow.com/request/4...
), HMRC revealed, with respect their decision to introduce a retrospective "new charge" going back 20 years, aimed specifically at contractors, and expected to cause grave distress to individuals who never broke any law, the following, astonishing facts:
"No estimate of the number of insolvencies was produced at the time the policy paper was
written."
and
"No estimate of the number of individuals affected by a breakdown of their family was produced"
This seems to suggest (and one would hope) that HMRC has since produced such assessments.
I am hereby asking HMRC:
1/ to indicate whether this is the case, and if so,
- the date
- the methodology used
- and the result of these assessments.
2/ How they have arrived to the figure in the following statement :
"this measure is expected to affect up to 40 000 individuals"
as found in the policy paper.
Recently, the Financial Secretary to the Treasury Mel Stride has been quoting the number 50 000 affected, which casts doubt on this figure and how it was obtained.
Please clarify the methodology followed and the calculations by which you have arrived to this figure.
Regards,
Chris Robinson
================================================================================
MESSAGE 2 [incoming]
HEADER: foi.team@hmrc.gsi.gov.uk on behalf of FOI Central Team,
HM Revenue and Customs
22 June 2018
--------------------------------------------------------------------------------
Our ref: FOI2018/01301
Dear Mr Robinson,
Freedom of Information Act 2000 Acknowledgement
Thank you for your communication of 21st June 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 for answer.
Yours sincerely
HMRC Freedom of Information Act Team
================================================================================
MESSAGE 3 [incoming]
HEADER: foi.team@hmrc.gsi.gov.uk on behalf of FOI Central Team,
HM Revenue and Customs
29 June 2018
--------------------------------------------------------------------------------
1 Attachment
FOI2018 01301 Robinson.pdf
246K
View
Download
Dear Mr Robinson
I am writing in response to your request for information, received on 21
June 2018.
Yours sincerely,
HMRC Freedom of Information Team
================================================================================
ATTACHMENT TEXT EXTRACTION / OCR
================================================================================
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ATTACHMENT: FOI2018_01109_Wright.pdf
TEXT_FILE: FOI2018_01109_Wright.pdf.txt
METHOD: pdf_native
OCR_USED: False
PAGES: 2
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--- PDF page 1 ---
Information is available in large print, audio and Braille formats.
Text Relay service prefix number – 18001
Individuals Policy Directorate
Freedom of Information Team
S1715
6 Floor
Central Mail Unit
Newcastle Upon Tyne
NE98 1ZZ
Mr Colin Wight
By email:
request-487899-bf64cba1@whatdotheyknow.com
Email
foi.request@hmrc.gsi.gov.uk
Web
www.gov.uk
Date: 14 June 2018
Our ref:
FOI2018/01109
Dear Mr Wight
Freedom of Information Act 2000 (FOIA)
Thank you for your request, which was received on 29 May, for the following information:
“In the Policy Paper: Tackling disguised remuneration - update (headed HM Revenue &
Customs) found here: https://www.gov.uk/government/publications/tackling-disguised-
remuneration-update/tackling-disguised-remuneration-update it is stated that "The
government anticipates that some of these individuals will become insolvent as a result." in
the Impact on individuals, households and families section.
Please tell me:
i) How many individuals were anticipated to become insolvent (from information at the time
of writing the Policy Paper)
ii) How many individuals are now expected to become insolvent (using up to date
information)
In the same document is is stated "This measure is expected to affect up to 40,000
individuals"
Please tell me:
iii) How many individuals are expected to be affected by the measures introduced following
the Policy Paper (Using up to date information)
iv) How many of the individuals affected will have be impacted by a breakdown of their
family (using up to date information)”
In response to part iii), I can confirm that we hold an estimate of the number of individuals
expected to be affected by the disguised remuneration (DR) 2019 loan charge. It is expected
to affect up to 50,000 individuals. Further information can be found here:
https://www.gov.uk/government/publications/disguised-remuneration-further-
update/disguised-remuneration-further-update
In response to parts i), ii) and iv), following a review of the records we hold, I have
established that HMRC does not hold the information you requested.
No estimate of the number of insolvencies was produced at the time the policy paper was
written. The policy paper contains an estimate of the Exchequer impact which includes an
--- PDF page 2 ---
2
inbuilt assumption to estimate the value of tax receipts lost to insolvencies. This is not given
on an individual level.
No further estimates of the number of individuals expected to become insolvent have been
produced.
The policy paper says that the measure “is not expected to have a material impact on family
formation, stability or breakdown”. No estimate of the number of individuals affected by a
breakdown of their family was produced. The policy paper assesses the impact of the loan
charge across the entire UK population, of which affected DR tax avoidance scheme users
make up a very small minority.
If you are not satisfied with this reply you may request a review within two months by
emailing foi.review@hmrc.gsi.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. The following link explains how to do this:
https://ico.org.uk/concerns/
Yours sincerely,
Individuals Policy Directorate
--------------------------------------------------------------------------------
ATTACHMENT: FOI2018_01301_Robinson.pdf
TEXT_FILE: FOI2018_01301_Robinson.pdf.txt
METHOD: pdf_native
OCR_USED: False
PAGES: 3
--------------------------------------------------------------------------------
--- PDF page 1 ---
Information is available in large print, audio and Braille formats.
Text Relay service prefix number – 18001
Counter-Avoidance
Freedom of Information Team
S1715
6 Floor
Central Mail Unit
Newcastle Upon Tyne
NE98 1ZZ
Mr Chris Robinson
By email:
request-489616-af799b23@whatdotheyknow.com
Email
foi.request@hmrc.gsi.gov.uk
Web
www.gov.uk
Date: 29 June 2018
Our ref:
FOI2018/01170 & FOI2018/01301
Dear Mr Robinson
Freedom of Information Act 2000 (FOIA)
Thank you for your requests, which were received on 6 and 21 June 2018, for the following
information:
FOI2018/01170
“In a response to a written question from Mr Roger Godsiff on the topic of the so-called
"2019 loan charge", Financial Secretary to the Treasury Mel Stride wrote the following on 5th
June 2018:
"Its announcement at Budget 2016 provided scheme users with a three year period to repay
their loans, or to agree a settlement with HMRC before the charge takes effect. The
government estimates that around 50,000 individuals are affected by this legislation".
Notwithstanding the contradiction in terms (it is unclear how "non-repayable" (according to
the Financial Secretary to the Treasury) loans could be repaid), we are requesting that HM
Revenue and Customs precise how many letters they have sent to the estimated 50000
"scheme users" affected by the legislation, since the Budget 2016 announcements and up to
the date of Mel Stride's statement, in order to inform them of the aforementioned options.”
FOI2018/01301
“In an answer dated 14 June 2018 to a FOI request made by Mr Colin Wight (link:
https://www.whatdotheyknow.com/request/487899/response/1176411/attach/2/FOI2018%20
01109%20Wright.pdf), HMRC revealed, with respect their decision to introduce a
retrospective "new charge" going back 20 years, aimed specifically at contractors, and
expected to cause grave distress to individuals who never broke any law, the following,
astonishing facts:
"No estimate of the number of insolvencies was produced at the time the policy paper was
written."
and
"No estimate of the number of individuals affected by a breakdown of their family was
produced"
This seems to suggest (and one would hope) that HMRC has since produced such
assessments.
I am hereby asking HMRC:
--- PDF page 2 ---
2
1/ to indicate whether this is the case, and if so,
- the date
- the methodology used
- and the result of these assessments.
2/ How they have arrived to the figure in the following statement :
"this measure is expected to affect up to 40 000 individuals"
as found in the policy paper.
Recently, the Financial Secretary to the Treasury Mel Stride has been quoting the number
50 000 affected, which casts doubt on this figure and how it was obtained.
Please clarify the methodology followed and the calculations by which you have arrived to
this figure.”
Under section 12(4) of the FOIA, with reference to regulation 5 of the Freedom of
Information and Data Protection (Appropriate Limit and Fees) Regulations 2004, when
estimating the cost of complying, HMRC may aggregate two or more requests made by the
same person, when the same or similar information is requested and where those requests
are received within a period of sixty consecutive days (see the links below).
http://www.legislation.gov.uk/ukpga/2000/36/section/12
http://www.legislation.gov.uk/uksi/2004/3244/regulation/5/made
I am therefore aggregating your requests and this response covers all three requests. I can
confirm that HMRC holds some information that falls within the scope of your requests.
However, we estimate that it would exceed the FOIA cost limit to deal with them. The cost
limit, which is specified in regulations, equates to one person spending 3½ working days
locating and extracting all of the information within scope of the request.
Normally, HMRC would explore with you how you might be able to narrow or refine your
request so that it did not exceed the FOIA cost limit. However, in this case, I cannot see any
scope for doing this.
HMRC published detailed settlement terms on 7 November 2017 as part of a campaign to
encourage taxpayers to come forward and settle their tax affairs ahead of the loan charge
introduction. We notified taxpayers through letters, emails, phone calls, and in webinars. To
provide number of taxpayers notified by letters would mean searching records across a
number of HMRC systems. We would have to review each record to identify the method of
notification used.
I have established that the time necessary to complete this task would exceed the cost limit
by some way. Consequently, under section 12(1) of the FOIA, HMRC is not obliged to
comply with your request and we will not be processing it further.
Although I am unable to answer your FOIA request, I can provide some information outside
of the Act on a discretionary basis.
Outside of the FOIA
You may be interested to know that at the end of 31 May 2018, we had recorded 20,919
registrations. However, this figure is subject to change as a number of interests received
close to the 31 May deadline still need to be logged.
If you are not satisfied with this reply you may request a review within two months by
emailing foi.review@hmrc.gsi.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. The following link explains how to do this:
https://ico.org.uk/concerns/
--- PDF page 3 ---
3
Yours sincerely,
Freedom of Information Team