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The Loan Charge 2019

Source: WhatDoTheyKnow
Authority: HM Revenue and Customs
Status: The request was refused by HM Revenue and Customs .
Imported path: /opt/loancharge/imports/wdtk/requests/the_loan_charge_2019

Open original request on WhatDoTheyKnow

Imported text

SOURCE: WhatDoTheyKnow
SOURCE_URL: https://www.whatdotheyknow.com/request/the_loan_charge_2019
TITLE: The Loan Charge 2019
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: the_loan_charge_2019
CAPTURED_AT: 2026-05-19T07:15:27+00:00
PROVENANCE: {"first_seen_at": "2026-05-18T12:55:03", "first_seen_page": "2", "first_query_term": "\"Loan Charge\"", "first_date_after": "2022/01/01", "first_date_before": "2023/01/01", "matched_query_terms": "\"Loan Charge\"", "matched_date_ranges": "2022/01/01 to 2023/01/01", "first_search_url_template": "https://www.whatdotheyknow.com/search/%22Loan%20Charge%22/requests?commit=Filter&query=%22Loan+Charge%22&request_date_after=2022%2F01%2F01&request_date_before=2023%2F01%2F01&request_variety%5B%5D=sent&request_variety%5B%5D=response&request_variety%5B%5D=comment&sortby=&utf8=%E2%9C%93&page="}

ATTACHMENTS:
- FOI2022_00298.pdf | https://www.whatdotheyknow.com/request/the_loan_charge_2019/response/1957843/attach/3/FOI2022%2000298.pdf?cookie_passthrough=1 | application/pdf | 194210 bytes
- [not downloaded] | https://www.whatdotheyknow.com/request/the_loan_charge_2019/response/1957843/attach/html/3/FOI2022%2000298.pdf.html |  | 0 bytes
- FOI2022_06787.pdf | https://www.whatdotheyknow.com/request/the_loan_charge_2019/response/1982349/attach/3/FOI2022%2006787.pdf?cookie_passthrough=1 | application/pdf | 198241 bytes
- [not downloaded] | https://www.whatdotheyknow.com/request/the_loan_charge_2019/response/1982349/attach/html/3/FOI2022%2006787.pdf.html |  | 0 bytes
- FOI2022_08656.pdf | https://www.whatdotheyknow.com/request/the_loan_charge_2019/response/1984618/attach/3/FOI2022%2008656.pdf?cookie_passthrough=1 | application/pdf | 207587 bytes
- [not downloaded] | https://www.whatdotheyknow.com/request/the_loan_charge_2019/response/1984618/attach/html/3/FOI2022%2008656.pdf.html |  | 0 bytes
- IR2022_09061.pdf | https://www.whatdotheyknow.com/request/the_loan_charge_2019/response/1986814/attach/3/IR2022%2009061.pdf?cookie_passthrough=1 | application/pdf | 195838 bytes
- [not downloaded] | https://www.whatdotheyknow.com/request/the_loan_charge_2019/response/1986814/attach/html/3/IR2022%2009061.pdf.html |  | 0 bytes

================================================================================
MESSAGE 1 [outgoing]
HEADER: Mr. Christopher Robinson
13 January 2022
Delivered
--------------------------------------------------------------------------------
Dear HM Revenue and Customs,
Please could you provide me with any letters/ communications, emails you have between you and  Mr Mel Stride whilst he was  serving as Financial Secretary to the Treasury with regards to the `Loan Charge'.
Yours faithfully,
Christopher Robinson

================================================================================
MESSAGE 2 [incoming]
HEADER: FOI Team,
        HM Revenue and Customs
13 January 2022
--------------------------------------------------------------------------------
Our ref: FOI2022/00298
Dear Mr Robinson,
Freedom of Information Act 2000 Acknowledgement
Thank you for your communication of 13 January.
We have allocated the above reference which you should quote if you need
to contact us.
We will arrange for a reply to be sent to you which will either comply
with our 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.
While we aim t o respond to all freedom of information requests within 20
working days, if for some reason this timescale cannot be complied with,
we will, where possible, write to you explaining the reason for the delay
and provide an estimated time for response.
Yours sincerely
HMRC Freedom of Information Team

================================================================================
MESSAGE 3 [incoming]
HEADER: FOI Team,
        HM Revenue and Customs
24 January 2022
--------------------------------------------------------------------------------
1 Attachment
FOI2022 00298.pdf
189K
View
Download
Dear Mr Robinson,
We are writing in response to your request for information, received 13
January.
Yours sincerely,
HMRC Freedom of Information Team

================================================================================
MESSAGE 4 [outgoing]
HEADER: Mr. Christopher Robinson
22 February 2022
Delivered
--------------------------------------------------------------------------------
Dear FOI Team,
Following on from FOI2022/00298 in which you asked for a narrowing down of the scope of the original request
I there fore would like to see communications between HMRC staff and Melvyn John Stride MP relating to the First issue of your newsletter `The Tiger's Roar'  as disclosed in FOI2021/24757. I am unaware of the actual date of issue due to the redaction of dating evidence.
Yours sincerely,
Mr. Christopher Robinson

================================================================================
MESSAGE 5 [incoming]
HEADER: FOI Team,
        HM Revenue and Customs
23 February 2022
--------------------------------------------------------------------------------
Our ref: FOI2022/06787
Dear Mr Robinson,
Freedom of Information Act 2000 Acknowledgement
Thank you for your communication of 22 February.
We have allocated the above reference which you should quote if you need
to contact us.
We will arrange for a reply to be sent to you which will either comply
with our 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.
While we aim to respond to all freedom of information requests within 20
working days, if for some reason this timescale cannot be complied with,
we will, where possible, write to you explaining the reason for the delay
and provide an estimated time for response.
Yours sincerely
HMRC Freedom of Information Team

================================================================================
MESSAGE 6 [incoming]
HEADER: FOI Team,
        HM Revenue and Customs
24 February 2022
--------------------------------------------------------------------------------
1 Attachment
FOI2022 06787.pdf
193K
View
Download
Dear Mr Robinson,
We are writing in response to your request for information, received 22
February.
Yours sincerely,
HMRC Freedom of Information Team

================================================================================
MESSAGE 7 [outgoing]
HEADER: Mr. Christopher Robinson
28 February 2022
Delivered
--------------------------------------------------------------------------------
Dear FOI Team,
“Following on from FOI2022/00298 in which you asked for a narrowing down of the scope of
the original request I there fore would like to see communications between HMRC staff and
Melvyn John Stride MP relating to the First issue of your newsletter `The Tiger's Roar' as
disclosed in FOI2021/24757. I am unaware of the actual date of issue due to the redaction of
dating evidence.”
`Whilst it is acknowledged that you have now narrowed the scope of your request to a
specific subject matter, compliance with your request would still require checking
correspondence to and from all HMRC staff. Such an exercise would far surpass the cost
limit. We can therefore neither confirm nor deny that we hold the information requested. This
should not be taken as indication that the information you seek is or is not held by us`.
For `All HMRC Staff' read `Counter Avoidance Staff'
Yours sincerely,
Mr. Christopher Robinson

================================================================================
MESSAGE 8 [incoming]
HEADER: FOI Team,
        HM Revenue and Customs
28 February 2022
--------------------------------------------------------------------------------
1 Attachment
FOI2022 08656.pdf
202K
View
Download
Dear Mr Robinson,
We are writing in response to your request for information, received 28
February.
Yours sincerely,
HMRC Freedom of Information Team

================================================================================
MESSAGE 9 [outgoing]
HEADER: Mr. Christopher Robinson
2 March 2022
Delivered
--------------------------------------------------------------------------------
Dear HM Revenue and Customs,
Please pass this on to the person who conducts Freedom of Information reviews.
I am writing to request an internal review of HM Revenue and Customs's handling of my FOI request 'The Loan Charge 2019'.
The information I have requested would be helpful to me in my considerations resulting from information disclosed in my FOI request FOI2021/24757.
A full history of my FOI request and all correspondence is available on the Internet at this address:
https://www.whatdotheyknow.com/request/t...
Yours faithfully,
Mr. Christopher Robinson

================================================================================
MESSAGE 10 [incoming]
HEADER: Team, FOI,
        HM Revenue and Customs
2 March 2022
--------------------------------------------------------------------------------
Our ref: IR2022/09061
Dear Mr Robinson,
Freedom of Information Act 2000 Acknowledgement
Thank you for your communication of 2 March.
We have allocated the above reference which you should quote if you need
to contact us.
We will arrange for a reply to be sent to you which will either comply
with our 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.
While we aim to re spond to all freedom of information requests within 20
working days, if for some reason this timescale cannot be complied with,
we will, where possible, write to you explaining the reason for the delay
and provide an estimated time for response.
Yours sincerely
HMRC Freedom of Information Team

================================================================================
MESSAGE 11 [incoming]
HEADER: Team, FOI,
        HM Revenue and Customs
2 March 2022
--------------------------------------------------------------------------------
1 Attachment
IR2022 09061.pdf
191K
View
Download
Dear Mr Robinson,
We are writing in response to your request for information, received 2
March.
Yours sincerely,
HMRC Freedom of Information Team

================================================================================
ATTACHMENT TEXT EXTRACTION / OCR
================================================================================

--------------------------------------------------------------------------------
ATTACHMENT: FOI2022_00298.pdf
TEXT_FILE: FOI2022_00298.pdf.txt
METHOD: pdf_native
OCR_USED: False
PAGES: 1
--------------------------------------------------------------------------------
--- PDF page 1 ---
If you need extra support, for example if you have a disability, a mental health condition, or 
do not speak English/Welsh, go to www.gov.uk and search for ‘get help from HMRC’. 
Text Relay service prefix number – 18001 
 
OFFICIAL 
 
Freedom of Information Team 
S1715 
6 Floor 
Central Mail Unit 
Newcastle Upon Tyne 
NE98 1ZZ 
Mr Christopher Robinson 
By email: request-821837-
163806aa@whatdotheyknow.com 
Email 
foi.request@hmrc.gov.uk 
Web 
www.gov.uk 
Date: 24 January 2022 
 
Our ref: 
FOI2022/00298 
 
 
Dear Mr Robinson 
 
Freedom of Information Act 2000 (FOIA) 
 
Thank you for your request, which was received on 13 January, for the following information: 
 
“Please could you provide me with any letters/ communications, emails you have between 
you and Mr Mel Stride whilst he was serving as Financial Secretary to the Treasury with 
regards to the `Loan Charge'.” 
 
We can confirm we hold the information you seek. However, providing it would exceed the 
FOIA cost limit, which for central government equates to one person spending 3½ working 
days locating and extracting all of the information requested. We have therefore refused 
your request under section 12(1) of the FOIA. 
 
You have requested any and all communications between HMRC officials and the Rt Hon 
Mel Stride during his time as Financial Secretary to the Treasury from June 2017 to May 
2019. Responding to your request would require checking correspondence to and from all 
HMRC staff over a nearly 2-year period. It is considered that to identify and collate such 
information would far surpass the cost limit. 
 
In order that information may be able to be provided, you may want to narrow the scope of 
your request by being more specific about the information you particularly wish to obtain. 
Alternatively, you may wish to make your request directly to HM Treasury. 
 
If you are not satisfied with our reply, you may request a review within 40 working days of 
receiving this letter by emailing foi.review@hmrc.gov.uk or by writing to our address at the 
top. 
 
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

--------------------------------------------------------------------------------
ATTACHMENT: FOI2022_06787.pdf
TEXT_FILE: FOI2022_06787.pdf.txt
METHOD: pdf_native
OCR_USED: False
PAGES: 2
--------------------------------------------------------------------------------
--- PDF page 1 ---
If you need extra support, for example if you have a disability, a mental health condition, or 
do not speak English/Welsh, go to www.gov.uk and search for ‘get help from HMRC’. 
Text Relay service prefix number – 18001 
OFFICIAL 
 
Freedom of Information Team 
S1715 
6 Floor 
Central Mail Unit 
Newcastle Upon Tyne 
NE98 1ZZ 
Mr Christopher Robinson 
By email: request-821837-
163806aa@whatdotheyknow.com 
Email 
foi.request@hmrc.gov.uk 
Web 
www.gov.uk 
Date: 24 February 2022 
 
Our ref: 
FOI2022/06787 
 
 
Dear Mr Robinson 
 
Freedom of Information Act 2000 (FOIA) 
 
Thank you for your request, which was received on 22 February, for the following 
information: 
 
“Following on from FOI2022/00298 in which you asked for a narrowing down of the scope of 
the original request I there fore would like to see communications between HMRC staff and 
Melvyn John Stride MP relating to the First issue of your newsletter `The Tiger's Roar' as 
disclosed in FOI2021/24757. I am unaware of the actual date of issue due to the redaction of 
dating evidence.” 
 
Section 1 of the FOIA places two duties on public authorities: 
 
Under section 1(1)(a), to confirm or deny if the requested information is held. 
Under section 1(1)(b), to disclose information that has been confirmed as being held. 
 
These obligations are however limited in appropriate circumstances to the cost restrictions 
set out beneath. 
 
Section 12(1) of the FOIA states a department is not obliged to comply with its duty under 
section 1(1)(b) above if doing so would exceed the cost limit. This limit, for central 
government, equates to one person spending 3½ working days locating and extracting all of 
the information requested. 
 
Section 12(2) of the FOIA similarly states that a department is not obliged to comply with 
paragraph (a) of section 1(1) above where the estimated cost of complying with that 
paragraph alone would exceed the appropriate limit. 
 
In FOI2021/28111, HMRC provided that ‘according to our records, the first edition (pages 4-
5) and the second edition (page 6) were issued in March 2017.’ 
 
Whilst it is acknowledged that you have now narrowed the scope of your request to a 
specific subject matter, compliance with your request would still require checking 
correspondence to and from all HMRC staff. Such an exercise would far surpass the cost 
limit. We can therefore neither confirm nor deny that we hold the information requested. This 
should not be taken as indication that the information you seek is or is not held by us.

--- PDF page 2 ---
2 
OFFICIAL 
 
 
In order that information may be able to be provided, you may want to narrow the scope of 
your request by being more specific about the information you particularly wish to obtain. 
Alternatively, you may wish to make your request directly to HM Treasury. 
 
If you are not satisfied with our reply, you may request a review within 40 working days of 
receiving this letter by emailing foi.review@hmrc.gov.uk or by writing to our address at the 
top. 
 
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

--------------------------------------------------------------------------------
ATTACHMENT: FOI2022_08656.pdf
TEXT_FILE: FOI2022_08656.pdf.txt
METHOD: pdf_native
OCR_USED: False
PAGES: 2
--------------------------------------------------------------------------------
--- PDF page 1 ---
If you need extra support, for example if you have a disability, a mental health condition, or 
do not speak English/Welsh, go to www.gov.uk and search for ‘get help from HMRC’. 
Text Relay service prefix number – 18001 
 
OFFICIAL 
 
Freedom of Information Team 
S1715 
6 Floor 
Central Mail Unit 
Newcastle Upon Tyne 
NE98 1ZZ 
Mr Christopher Robinson 
By email: request-821837-
163806aa@whatdotheyknow.com 
 
Email 
foi.request@hmrc.gov.uk 
Web 
www.gov.uk 
Date: 28 February 2022 
 
Our ref: 
FOI2022/08656 
 
 
Dear Mr Robinson 
 
Freedom of Information Act 2000 (FOIA) 
 
Thank you for your request, which was received on 28 February, for the following 
information: 
 
“"Following on from FOI2022/00298 in which you asked for a narrowing down of the scope 
of 
 
the original request I there fore would like to see communications between HMRC staff and 
 
Melvyn John Stride MP relating to the First issue of your newsletter `The Tiger's Roar' as 
 
disclosed in FOI2021/24757. I am unaware of the actual date of issue due to the redaction of 
 
dating evidence." 
 
`Whilst it is acknowledged that you have now narrowed the scope of your request to a 
 
specific subject matter, compliance with your request would still require checking 
 
correspondence to and from all HMRC staff. Such an exercise would far surpass the cost 
 
limit. We can therefore neither confirm nor deny that we hold the information requested. This 
 
should not be taken as indication that the information you seek is or is not held by us`. 
 
 
 
For `All HMRC Staff' read `Counter Avoidance Staff'” 
 
The emphasis on protecting public authorities’ resources from unreasonable requests was 
acknowledged by the Upper Tribunal in the case of Information Commissioner vs Devon 
County Council & Dransfield [2012] UKUT 440 (AAC), (28 January 2013) when it defined the 
purpose of section 14 as follows; 
 
‘Section 14…is concerned with the nature of the request and has the effect of disapplying 
the citizen’s right under Section 1(1)…The purpose of Section 14…must be to protect the

--- PDF page 2 ---
2 
OFFICIAL 
resources (in the broadest sense of that word) of the public authority from being squandered 
on disproportionate use of FOIA…’ (paragraph 10). 
 
A request which would not normally be regarded as vexatious in isolation may assume that 
quality once considered in context. An example of this would be where an individual is 
placing a significant strain on an authority’s resources by submitting a long and frequent 
series of requests, and the most recent request, although not obviously vexatious in itself, is 
contributing to that aggregated burden. 
 
In Information Commissioner vs Devon County Council & Dransfield [2012] UKUT 440 
(AAC), (28 January 2013), Judge Wikeley recognised that the Upper Tribunal in Wise v The 
Information Commissioner (GIA/1871/2011) had identified proportionality as the common 
theme underpinning section 14(1) and he made particular reference to its comment that: 
 
‘Inherent in the policy behind section 14(1) is the idea of proportionality. There must be an 
appropriate relationship between such matters as the information sought, the purpose of the 
request, and the time and other resources that would be needed to provide it.’ 
 
HMRC has received 20 information requests from you, concerning various aspects of the 
Loan Charge in the past 2 months. Three of your requests seek copies of the same 
information, in many cases your requests are so broad that they clearly would exceed the 
FOIA cost limit. 
 
HMRC has previously advised that your requests do not seek specific information and you 
have been directed to ICO guidance on making effective information requests. 
 
Having considered all factors associated with your series of requests, I do not find their 
serious purpose to outweigh the aggregated impact on the department. 
 
If you are not satisfied with our reply, you may request a review within 40 working days of 
receiving this letter by emailing foi.review@hmrc.gov.uk or by writing to our address at the 
top. 
 
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

--------------------------------------------------------------------------------
ATTACHMENT: IR2022_09061.pdf
TEXT_FILE: IR2022_09061.pdf.txt
METHOD: pdf_native
OCR_USED: False
PAGES: 2
--------------------------------------------------------------------------------
--- PDF page 1 ---
If you need extra support, for example if you have a disability, a mental health condition, or 
do not speak English/Welsh, go to www.gov.uk and search for ‘get help from HMRC’. 
Text Relay service prefix number – 18001 
 
OFFICIAL 
 
Freedom of Information Team 
S1715 
6 Floor 
Central Mail Unit 
Newcastle Upon Tyne 
NE98 1ZZ 
Mr Christopher Robinson 
By email: request-821837-
163806aa@whatdotheyknow.com 
 
Email 
foi.request@hmrc.gov.uk 
Web 
www.gov.uk 
Date: 2 March 2022 
 
Our ref: 
IR2022/09061 
 
 
Dear Mr Robinson 
 
Freedom of Information Act 2000 (FOIA) 
 
Thank you for your email of 2 March, which seeks a review of our original response to your 
information request. Your initial request was considered under section 14(1) FOIA in 
conjunction with a number of other requests recently made by you. 
 
I can advise that were HMRC to consider this specific request in isolation it would be refused 
by virtue of section 12(2) FOIA. 
 
Section 1 of the FOIA places two duties on public authorities: 
 
Under section 1(1)(a), to confirm or deny if the requested information is held. 
Under section 1(1)(b), to disclose information that has been confirmed as being held. 
 
These obligations are however limited in appropriate circumstances to the cost restrictions 
set out beneath. 
 
Section 12(1) of the FOIA states a department is not obliged to comply with its duty under 
section 1(1)(b) above if doing so would exceed the cost limit. This limit, for central 
government, equates to one person spending 3½ working days locating and extracting all of 
the information requested. 
 
Section 12(2) of the FOIA similarly states that a department is not obliged to comply with 
paragraph (a) of section 1(1) above where the estimated cost of complying with that 
paragraph alone would exceed the appropriate limit. 
 
In FOI2021/28111, HMRC provided that ‘according to our records, the first edition (pages 4-
5) and the second edition (page 6) were issued in March 2017.’ 
 
Whilst it is acknowledged that you have now narrowed the scope of your request to those 
staff within the department’s Counter Avoidance directorate, compliance with your request 
would still require checking correspondence to and from over 1,400 staff. Such an exercise 
would far surpass the cost limit. We can therefore neither confirm nor deny that we hold the 
information requested. This should not be taken as indication that the information you seek 
is or is not held by us.

--- PDF page 2 ---
2 
OFFICIAL 
As before, we would advise you to direct such a request to HM Treasury. 
 
If you are not content with the outcome of this internal review you can complain to the 
Information Commissioner’s Office. 
 
 
 
Yours sincerely, 
 
HM Revenue and Customs