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The loan Charge and PD1 - take 2

Source: WhatDoTheyKnow
Authority: HM Revenue and Customs
Status: The request was partially successful .
Imported path: /opt/loancharge/imports/wdtk/requests/the_loan_charge_and_pd1_take_2

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Imported text

SOURCE: WhatDoTheyKnow
SOURCE_URL: https://www.whatdotheyknow.com/request/the_loan_charge_and_pd1_take_2
TITLE: The loan Charge and PD1 - take 2
AUTHORITY: HM Revenue and Customs
AUTHORITY_URL: https://www.whatdotheyknow.com/body/hmrc
STATUS: The request was
partially successful
.
REQUEST_SLUG: the_loan_charge_and_pd1_take_2
CAPTURED_AT: 2026-05-19T07:15:58+00:00
PROVENANCE: {"first_seen_at": "2026-05-18T12:52:26", "first_seen_page": "2", "first_query_term": "\"Loan Charge\"", "first_date_after": "2019/01/01", "first_date_before": "2020/01/01", "matched_query_terms": "\"Loan Charge\" | \"disguised remuneration\"", "matched_date_ranges": "2019/01/01 to 2020/01/01 | 2020/01/01 to 2021/01/01", "first_search_url_template": "https://www.whatdotheyknow.com/search/%22Loan%20Charge%22/requests?commit=Filter&query=%22Loan+Charge%22&request_date_after=2019%2F01%2F01&request_date_before=2020%2F01%2F01&request_variety%5B%5D=sent&request_variety%5B%5D=response&request_variety%5B%5D=comment&sortby=&utf8=%E2%9C%93&page="}

ATTACHMENTS:
- FOI_Response.pdf | https://www.whatdotheyknow.com/request/the_loan_charge_and_pd1_take_2/response/1498064/attach/2/FOI%20Response.pdf?cookie_passthrough=1 | application/pdf | 105507 bytes
- [not downloaded] | https://www.whatdotheyknow.com/request/the_loan_charge_and_pd1_take_2/response/1498064/attach/html/2/FOI%20Response.pdf.html |  | 0 bytes

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MESSAGE 1 [outgoing]
HEADER: Philip Harris
9 December 2019
Delivered
--------------------------------------------------------------------------------
Dear HM Revenue and Customs,
Earlier this year I raised an FOI about PD1 - your response, now more than 2 months old neglected to answer the following questions I raised:
How many people in (or were in) PD1  affected by the Loan Charge have had settlement offers below 100% of the tax due - ie how many have received special settlement offers
Without disclosing personal information please detail the tax due and the settlement amounts
How many people in (or were in) PD1 that could be affected by the Loan Charge have had that tax obligation reduced to zero or have been assured that they will not have the Loan Charge imposed upon them?
Yours faithfully,
Philip Harris

================================================================================
MESSAGE 2 [incoming]
HEADER: foi.team@hmrc.gsi.gov.uk on behalf of FOI Central Team,
        HM Revenue and Customs
10 December 2019
--------------------------------------------------------------------------------
Our ref: FOI2019/02603
Dear Mr Harris,
Freedom of Information Act 2000 Acknowledgement
Thank you for your communication of 9th December 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
9 January 2020
--------------------------------------------------------------------------------
1 Attachment
FOI Response.pdf
103K
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Dear Mr Harris,
I am writing in response to your request for information, received 9th
December.
Yours sincerely,
HMRC Freedom of Information Team

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ATTACHMENT TEXT EXTRACTION / OCR
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ATTACHMENT: FOI_Response.pdf
TEXT_FILE: FOI_Response.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 
 
 
 
Freedom of Information Team 
S1715 
6 Floor 
Central Mail Unit 
Newcastle Upon Tyne 
NE98 1ZZ 
Mr Philip Harris 
By email: 
request-626256-36f207a8@whatdotheyknow.com 
Email 
foi.request@hmrc.gov.uk 
Web 
www.gov.uk 
Date: 9 January 2020 
 
Our ref: 
FOI2019/02603 
 
 
Dear Mr Harris 
 
Freedom of Information Act 2000 (FOIA) 
 
Thank you for your request, which was received on 9 December, for the following 
information: 
 
“Earlier this year I raised an FOI about PD1 - your response, now more than 2 months old 
neglected to answer the following questions I raised: 
 
How many people in (or were in) PD1 affected by the Loan Charge have had settlement 
offers below 100% of the tax due - ie how many have received special settlement offers 
Without disclosing personal information please detail the tax due and the settlement 
amounts 
 
How many people in (or were in) PD1 that could be affected by the Loan Charge have had 
that tax obligation reduced to zero or have been assured that they will not have the Loan 
Charge imposed upon them?” 
 
All the settled cases referred to in our previous response FOI2019/00963 were made in 
accordance with the published settlement terms. Further information about the settlement 
terms is available on GOV.UK. There is no special treatment for any group of customers, we 
treat all taxpayers fairly and enforce the existing tax rules impartially. We are subject to 
rigorous governance procedures to ensure that all taxpayers are treated fairly and equally. 
 
You might be interested to know that in September 2019, the Chancellor commissioned an 
independent review into the Disguised Remuneration (DR) Loan Charge, the review has 
now concluded. The Government has now published the review, and its response, accepting 
all but one of its recommendations. The Government intends to legislate to implement these 
recommendations in the next Finance Bill. Further guidance for those affected, with the 
review and the Government’s response can be found here. 
 
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.

--- PDF page 2 ---
2 
 
Yours sincerely, 
 
Freedom of Information Team