Tax Avoidance:Written question - 152724 - estimates of schemes

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Authority: HM Treasury
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SOURCE: WhatDoTheyKnow
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TITLE: Tax Avoidance:Written question - 152724 - estimates of schemes
AUTHORITY: HM Treasury
AUTHORITY_URL: https://www.whatdotheyknow.com/body/hm_treasury
STATUS: The request was
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REQUEST_SLUG: tax_avoidancewritten_question_15_8
CAPTURED_AT: 2026-05-19T07:12:04+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\" | \"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="}

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MESSAGE 1 [outgoing]
HEADER: Chris Sawyer
22 June 2018
Delivered
--------------------------------------------------------------------------------
Dear Her Majesty’s Treasury,
With reference to "Tax Avoidance:Written question - 152724" found here
https://www.parliament.uk/business/publi...
Stride's answer says "No estimate has been made of the number of schemes currently operating in the UK."
Can I please have the following information:
1a) When the 2019 Loan Charge was proposed to Treasury Ministers by HMRC in September 2015 and in period following until the legislation was introduced, was any estimate made of the number of schemes in operation provided to the Treasury by HMRC (or any other body)?
1b) If there was an estimate provided, can you please give me the estimated figures?
1c) If no estimate was provided to the Treasury by HMRC (or any other body), can you please tell me if estimates of the number of schemes were made by the Treasury and were then used in the process to accept HMRC's proposal for the 2019 Loan Charge?
1d) If no estimates of the number of schemes were used in the process to accept HMRC's proposal for the 2019 Loan Charge, can you tell me if it is standard policy for the Treasury to accept HMRC's proposals without knowing the impact of such proposals?
1e) If no estimates of the number of schemes were used in the process to accept HMRC's proposal for the 2019 Loan Charge, was the Treasury's acceptance of the proposal based on the number of individuals who would be subjected to the 2019 Loan Charge rather than the number of schemes?
I would also like the following information:
2a) When deciding whether to create legislation for HMRC's proposals, how does the Treasury determine if creating legislation will be cost effective?
2b) Can any documents be provided which detail the processes used by the Treasury when deciding to accept proposals from HMRC?
2c) Is any human impact analysis (mental health effects on HMRC customers or expected suicides of HMRC customers as examples) performed by the Treasury or any other body when considering HMRC's proposals?
Yours faithfully,
Chris Sawyer

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MESSAGE 2 [incoming]
HEADER: FOI Requests,
        HM Treasury
22 June 2018
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MESSAGE 3 [incoming]
HEADER: FOI Requests,
        HM Treasury
19 July 2018
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Dear Mr Sawyer
Please find attached a letter in response to your Freedom of Information
request.
For ease of reference, the attached letter contains the following
clickable hyperlinks
[1]
https://www.gov.uk/government/publicatio...
[2]
https://www.gov.uk/government/publicatio...
Yours sincerely
Information Rights Unit | HM Treasury, 1 Horse Guards Road, London, SW1A
2HQ   [3]www.gov.uk/hm-treasury
This email and any files transmitted with it are intended solely for the
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http://www.gov.uk/hm-treasury

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--- PDF page 1 ---
1 Horse Guards Road
HM Treasury 
London
SW1A 2HQ
Information Rights Unit
HM Treasury
Chris Sawyer 
020 7270 5000
foirequests@hmtreasury.gov.uk
www.gov.uk/hm-treasury
Via email: request-492648-
bbc74f41@whatdotheyknow.com 
19 July 2018
Ref: FOI2018/11222
Dear Mr Sawyer
Freedom of Information Act 2000: 2019 Loan Charge
Thank you for your enquiry of 22 June 2018, which we have considered under the terms of
the Freedom of Information Act 2000 (the FOI Act).
You asked for the following information:
“1a) When the 2019 Loan Charge was proposed to Treasury Ministers by HMRC in
September 2015 
and in period following until the legislation was introduced, was
any estimate made of the number of schemes in operation provided to the
Treasury by HMRC (or any other-body)?
1b) If there was an estimate provided, can you please give me the estimated
figures?
1¢) If no estimate was provided to the Treasury by HMRC (or any other body), can
you please tell me if estimates of the number of schemes were made by the
Treasury and were then used in the process to accept HMRCs proposal for the
2019 Loan Charge?
1d) If no estimates of the number of schemes were used in the process to accept
HMRCs proposal for the 2019 Loan Charge, can you tell me if it is standard policy
for the Treasury to accept HMRC's proposals without knowing the impact of such
proposals?
Te) If no estimates of the number of schemes were used in the process to accept
HMRC proposal for the 2019 Loan Charge, was the Treasury's acceptance of the
proposal based on the number of individuals who would be subjected to the 2019
Loan Charge rather than the number of schemes?
! would also like the following information:
2a) When deciding whether to create legislation for HMRC's proposals, how does
the Treasury determine if creating legislation will be cost effective?
2b) Can any documents be provided which detail the processes used by the
Treasury when deciding to accept proposals from HMRC?
2¢) Is any human impact analysis (mental health effects on HMRC customers or
expected suicides of HMRC customers as examples) performed by the Treasury or
any other body when considering HMRCss proposals?”

--- PDF page 2 ---
| can confirm that HM Treasury does hold information within the scope of your request.
Some of the questions you have asked are seeking explanations or yes / no answers. As
such they do not strictly constitute requests for recorded information. Some explanations
and answers have been given to be helpful and are outside of our obligations under the
FOI Act.
In response to question 1a) | can confirm that no estimate has been made of the number
of schemes currently operating in the UK, as stated in the Parliamentary Question you
reference in the preface to your request.
HM Revenue and Customs (HMRC) provided analysis to HM Treasury on the impact of the
proposals to extend the Disguised Remuneration legislation. The analysis included an
estimate of the number of individuals who would be affected by the charge, the total tax
at stake and the average tax charge that would arise for those affected by the charge.
Information relevant to your request has already been published. Under section 21 of the
FOI Act, departments are not obliged to re-issue information where it is already publically
accessible. We have however, included the link to this below:
https://www.gov.uk/government/publications/disquised-remuneration-further-
update/disquised-remuneration-further-update
Analysis of the exchequer impacts of any change to the tax legislation is provided to HM
Treasury by HMRC. HMRC also provide an estimate of the costs for HMRC of any proposal.
HMRC were provided with additional financial resources at Budget 2016 to implement the
package of changes to tackle disguised remuneration avoidance schemes, including the
Loan Charge. See the link below for further details.
https://www.gov.uk/government/publications/tackling-disquised-remuneration-
update/tackling-disguised-remuneration-update
The published documents include some information on the impact on individuals and
businesses.
In relation to question 2b, the request is expressed in very general terms and we would
need you to be more specific to enable us to identify relevant information.
If you have any queries about this letter, please contact us. Please quote the reference
number above in any future communications.
Yours sincerely
Information Rights Unit

--- PDF page 3 ---
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Your right to complain under the Freedom of Information Act 2000
If you are not happy with this reply, you can request a review by writing to HM Treasury,
Information Rights Unit, 
1 Horse Guards Road, London SW1A 2HQ or by emailing us at the
address below. Any review request must be made within 2 months of the date of this
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Email: foirequests@hmtreasury.gov.uk
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Loan Charge FOI

Tax Avoidance:Written question - 152724 - estimates of schemes

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Loan Charge FOI
