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The number of DR Open enquiry and closed enquiry

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

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SOURCE: WhatDoTheyKnow
SOURCE_URL: https://www.whatdotheyknow.com/request/the_number_of_dr_open_enquiry_an
TITLE: The number of DR Open enquiry and closed enquiry
AUTHORITY: HM Revenue and Customs
AUTHORITY_URL: https://www.whatdotheyknow.com/body/hmrc
STATUS: The request was
partially successful
.
REQUEST_SLUG: the_number_of_dr_open_enquiry_an
CAPTURED_AT: 2026-05-19T07:16:17+00:00
PROVENANCE: {"first_seen_at": "2026-05-18T12:53:55", "first_seen_page": "2", "first_query_term": "\"Loan Charge\"", "first_date_after": "2021/01/01", "first_date_before": "2022/01/01", "matched_query_terms": "\"Loan Charge\" | \"disguised remuneration\"", "matched_date_ranges": "2021/01/01 to 2022/01/01", "first_search_url_template": "https://www.whatdotheyknow.com/search/%22Loan%20Charge%22/requests?commit=Filter&query=%22Loan+Charge%22&request_date_after=2021%2F01%2F01&request_date_before=2022%2F01%2F01&request_variety%5B%5D=sent&request_variety%5B%5D=response&request_variety%5B%5D=comment&sortby=&utf8=%E2%9C%93&page="}

ATTACHMENTS:
- 20210312_FOI2021_01904.pdf | https://www.whatdotheyknow.com/request/the_number_of_dr_open_enquiry_an/response/1748266/attach/3/20210312%20FOI2021%2001904.pdf?cookie_passthrough=1 | application/pdf | 123226 bytes
- [not downloaded] | https://www.whatdotheyknow.com/request/the_number_of_dr_open_enquiry_an/response/1748266/attach/html/3/20210312%20FOI2021%2001904.pdf.html |  | 0 bytes

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MESSAGE 1 [outgoing]
HEADER: Trevor Price
22 February 2021
Delivered
--------------------------------------------------------------------------------
Dear HM Revenue and Customs,
With reference to the Sir A Morse Loan Charge Report. I would like up to date figures for the following:
How many people have been identified up to the present date who met the following criteria? ‘Where an enquiry had been opened into that customer’s use of a disguised remuneration scheme, and the enquiry was subsequently closed with the conclusion that tax was not due on any loans received’
Yours faithfully,
Trevor Price

================================================================================
MESSAGE 2 [incoming]
HEADER: FOI Central Team,
        HM Revenue and Customs
22 February 2021
--------------------------------------------------------------------------------
Our ref: FOI2021/01904
Dear Mr Price,
Freedom of Information Act 2000 Acknowledgement
Thank you for your communication of 22nd February 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 f or answer.
As you will appreciate, the coronavirus pandemic has provided
unprecedented challenges for Government Departments including HMRC. Over
the coming weeks our priorities are to provide critical existing and new
Public Services for Government to support customers during this difficult
time. As a result, resources may be diverted away from usual compliance or
information rights work. HMRC aims to respond to all FOIA Requests within
20 working days. If for whatever reason this timescale cannot be complied
with HMRC will, where possible, write to you explaining the reason for the
delay and providing an estimated time for response.
Yours sincerely
HMRC Freedom of Information Act Team

================================================================================
MESSAGE 3 [incoming]
HEADER: FOI Central Team,
        HM Revenue and Customs
17 March 2021
--------------------------------------------------------------------------------
1 Attachment
20210312 FOI2021 01904.pdf
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Dear Mr Price
We are writing in response to your request for information, received 22
February 2021.
Yours sincerely,
HMRC Freedom of Information Team

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ATTACHMENT TEXT EXTRACTION / OCR
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ATTACHMENT: 20210312_FOI2021_01904.pdf
TEXT_FILE: 20210312_FOI2021_01904.pdf.txt
METHOD: pdf_native
OCR_USED: False
PAGES: 1
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--- PDF page 1 ---
Information is available in large print, audio and Braille formats. 
Text Relay service prefix number – 18001 
 
 
OFFICIAL 
 
Freedom of Information Team 
S1715 
6 Floor 
Central Mail Unit 
Newcastle Upon Tyne 
NE98 1ZZ 
Mr Trevor Price 
By email: 
request-730473-f38b1eb3@whatdotheyknow.com 
Email 
foi.request@hmrc.gov.uk 
Web 
www.gov.uk 
Date: 17 March 2021 
 
Our ref: 
FOI2021/01904 
 
 
Dear Mr Price 
 
Freedom of Information Act 2000 (FOIA) 
 
Thank you for your request, which was received on 22 February, for the following 
information: 
 
“With reference to the Sir A Morse Loan Charge Report. I would like up to date figures for 
the following: 
How many people have been identified up to the present date who met the following criteria? 
‘Where an enquiry had been opened into that customer’s use of a disguised remuneration 
scheme, and the enquiry was subsequently closed with the conclusion that tax was not due 
on any loans received’” 
 
We have interpreted your request as seeking information about individuals who have 
benefited from the Government’s commitment that the Loan Charge will not apply where 
HMRC have previously closed enquiries without charging additional tax, please let us know 
if this is not the case. 
 
We can confirm that we are not aware of any taxpayers where we need to act to carry out 
this commitment. We invited customers and external stakeholders to come forward to share 
any cases they are aware of, but we have not identified any taxpayers for whom these 
circumstances have arisen, as explained at paragraph 1.18 of HMRC’s report on 
implementation of the Loan Charge review. 
 
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. 
 
Yours sincerely, 
 
HM Revenue and Customs