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Transfer of liability for the 2019 Loan Charge
Source: WhatDoTheyKnow
Authority: HM Revenue and Customs
Status: The request was
successful
.
Imported path: /opt/loancharge/imports/wdtk/requests/transfer_of_liability_for_the_20
Open original request on WhatDoTheyKnow
Imported text
SOURCE: WhatDoTheyKnow
SOURCE_URL: https://www.whatdotheyknow.com/request/transfer_of_liability_for_the_20
TITLE: Transfer of liability for the 2019 Loan Charge
AUTHORITY: HM Revenue and Customs
AUTHORITY_URL: https://www.whatdotheyknow.com/body/hmrc
STATUS: The request was
successful
.
REQUEST_SLUG: transfer_of_liability_for_the_20
CAPTURED_AT: 2026-05-19T07:17:37+00:00
PROVENANCE: {"first_seen_at": "2026-05-18T12:51:34", "first_seen_page": "2", "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="}
ATTACHMENTS:
- FOI2018_01737_Final.pdf | https://www.whatdotheyknow.com/request/transfer_of_liability_for_the_20/response/1228407/attach/2/FOI2018%2001737%20Final.pdf?cookie_passthrough=1 | application/pdf | 154535 bytes
- [not downloaded] | https://www.whatdotheyknow.com/request/transfer_of_liability_for_the_20/response/1228407/attach/html/2/FOI2018%2001737%20Final.pdf.html | | 0 bytes
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MESSAGE 1 [outgoing]
HEADER: Andrew Saunders
7 August 2018
Delivered
--------------------------------------------------------------------------------
Dear HM Revenue and Customs,
The 2019 Loan Charge legislation allows (under certain circumstances) the charge to be collected through a transfer of liability from employer to employee.
1. how many individuals do HMRC estimate will require the tax liability to be transferred from the employer to the individual using the 2019 Loan Charge? (presumably this has been done to estimate the resources required for the task)
2. of those individuals how many are estimated to have the liability transferred to them because their employers are no longer in existence?
Yours faithfully,
Andrew Saunders
================================================================================
MESSAGE 2 [incoming]
HEADER: foi.team@hmrc.gsi.gov.uk on behalf of FOI Central Team,
HM Revenue and Customs
8 August 2018
--------------------------------------------------------------------------------
Our ref: FOI2018/01737
Dear Andrew Saunders,
Freedom of Information Act 2000 Acknowledgement
Thank you for your communication of 7th August 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
5 September 2018
--------------------------------------------------------------------------------
1 Attachment
FOI2018 01737 Final.pdf
150K
View
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Dear Mr Saunders,
I am writing in response to your request for information, received 7
August 2018.
Yours sincerely,
HMRC Freedom of Information Team
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ATTACHMENT TEXT EXTRACTION / OCR
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ATTACHMENT: FOI2018_01737_Final.pdf
TEXT_FILE: FOI2018_01737_Final.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
Counter-Avoidance
Freedom of Information Team
S1715
6 Floor
Central Mail Unit
Newcastle Upon Tyne
NE98 1ZZ
Mr Andrew Saunders
By email: request-508363-
957db12a@whatdotheyknow.com
Email
foi.request@hmrc.gsi.gov.uk
Web
www.gov.uk
Date: 5 September 2018
Our ref:
FOI2018/01737
Dear Mr Saunders
Freedom of Information Act 2000 (FOIA)
Thank you for your request, which was received on 7 August, for the following information:
The 2019 Loan Charge legislation allows (under certain circumstances) the charge to be
collected through a transfer of liability from employer to employee.
1. how many individuals do HMRC estimate will require the tax liability to be transferred from
the employer to the individual using the 2019 Loan Charge? (presumably this has been done
to estimate the resources required for the task)
2. of those individuals how many are estimated to have the liability transferred to them
because their employers are no longer in existence?
Pay As You Earn (PAYE) liabilities fall on the employer in the first instance. The charge on
Disguised Remuneration (DR) loans will not change this principle and HMRC will pursue
employers who have used DR schemes for the tax that is due. 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.
The number of cases where liability will be transferred from the employer to the individual
will be dependent on the number of people who come forward to settle their tax affairs
before April 2019. DR ‘settlement terms’ were published on 7 November 2017 and we are
currently working with those who have come forward to resolve their tax affairs. Further
information is available at: www.gov.uk/government/publications/disguised-remuneration-
detailed-settlement-terms/disguised-remuneration-detailed-settlement-terms
Although no formal estimates have made regarding the number of cases where liability is
expected to be transferred from the employer to the individual or where the employer is no
longer in existence this has been considered as part of the overall resourcing requirements
in respect of the settlement of DR cases.
Information regarding the resources required to support the settlement of DR cases is
available in our response to the following information request published on
whatdotheyknow.com at: https://www.whatdotheyknow.com/request/settlement_resources
--- PDF page 2 ---
2
If you are not satisfied with this reply you may request a review within two months by
emailing foi.review@hmrc.gsi.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 make a complaint to
the Information Commissioner’s Office (ICO). Instructions about this process are available at
the following link: https://ico.org.uk/concerns/
Yours sincerely,
Freedom of Information Team