Tax Avoidance:Written question - 152724 - enquiry time limits and the 2019 Loan Charge

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/tax_avoidancewritten_question_15_11

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SOURCE: WhatDoTheyKnow
SOURCE_URL: https://www.whatdotheyknow.com/request/tax_avoidancewritten_question_15_11
TITLE: Tax Avoidance:Written question - 152724 - enquiry time limits and the 2019 Loan Charge
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: tax_avoidancewritten_question_15_11
CAPTURED_AT: 2026-05-19T07:11:17+00:00
PROVENANCE: {"first_seen_at": "2026-05-18T12:51:27", "first_seen_page": "1", "first_query_term": "\"Loan Charge\"", "first_date_after": "2018/01/01", "first_date_before": "2019/01/01", "matched_query_terms": "\"Loan Charge\"", "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="}

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MESSAGE 1 [outgoing]
HEADER: Chris Sawyer
22 June 2018
Delivered
--------------------------------------------------------------------------------
Dear HM Revenue and Customs,
With reference to "Tax Avoidance:Written question - 152724" found here
https://www.parliament.uk/business/publi...
Stride's answer says "HMRC will only go to the employee to settle their income tax liability in cases where it cannot reasonably be collected from the employer, for example where the employer is no longer in existence."
He also says "However, these schemes never worked and the amounts paid were always taxable under the law at the time."
For individuals and employers who were involved in arrangements expected to be subjected to the 2019 Loan Charge
1) Please tell me how many individuals will be taxed under the 2019 Loan Charge where their employer is no longer in existence.
2) Please tell me how many employers went out of existence while under tax avoidance enquiries by HMRC.
3) Please tell me how many employers that are no longer in existence but should have paid income tax liability under the law at the time they were in existence will have that income tax liability transferred to individuals via the 2019 Loan Charge.
Where HMRC failed to open an enquiry on a taxpayer or employer/scheme:
4) Can please give me the number of individuals that will have income tax liability transferred to them (from the employer) under the 2019 Loan Charge that could not be transferred to them on 5/4/19 (using the law at the time the amounts were paid) as standard enquiry time limits will no longer be available for HMRC to open an enquiry.
Yours faithfully,
Chris Sawyer

================================================================================
MESSAGE 2 [incoming]
HEADER: foi.team@hmrc.gsi.gov.uk on behalf of FOI Central Team,
        HM Revenue and Customs
25 June 2018
--------------------------------------------------------------------------------
Our ref: FOI2018/01307
Dear Mr Sawyer,
Freedom of Information Act 2000 Acknowledgement
Thank you for your communication of 22nd 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

Loan Charge FOI

Tax Avoidance:Written question - 152724 - enquiry time limits and the 2019 Loan Charge

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Loan Charge FOI