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Using a combination of both the CLSO and the 2019 Loan Charge
Source: WhatDoTheyKnow
Authority: HM Revenue and Customs
Status: Response to this request is
long overdue
. By law, under all circumstances,
HM Revenue and Customs
should have responded by now (
details
). The person who made the request can
complain
by
requesting an internal review
.
Imported path: /opt/loancharge/imports/wdtk/requests/using_a_combination_of_both_the
Open original request on WhatDoTheyKnow
Imported text
SOURCE: WhatDoTheyKnow
SOURCE_URL: https://www.whatdotheyknow.com/request/using_a_combination_of_both_the
TITLE: Using a combination of both the CLSO and the 2019 Loan Charge
AUTHORITY: HM Revenue and Customs
AUTHORITY_URL: https://www.whatdotheyknow.com/body/hmrc
STATUS: Response to this request is
long overdue
. By law, under all circumstances,
HM Revenue and Customs
should have responded by now (
details
). The person who made the request can
complain
by
requesting an internal review
.
REQUEST_SLUG: using_a_combination_of_both_the
CAPTURED_AT: 2026-05-19T07:22:15+00:00
PROVENANCE: {"first_seen_at": "2026-05-18T12:51:45", "first_seen_page": "3", "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_00360_Leggsy.pdf | https://www.whatdotheyknow.com/request/using_a_combination_of_both_the/response/1120962/attach/2/FOI2018%2000360%20Leggsy.pdf?cookie_passthrough=1 | application/pdf | 151999 bytes
- [not downloaded] | https://www.whatdotheyknow.com/request/using_a_combination_of_both_the/response/1120962/attach/html/2/FOI2018%2000360%20Leggsy.pdf.html | | 0 bytes
- FOI2018_00360_Leggsy_003.pdf | https://www.whatdotheyknow.com/request/using_a_combination_of_both_the/response/1165014/attach/2/FOI2018%2000360%20Leggsy.pdf?cookie_passthrough=1 | application/pdf | 151999 bytes
- [not downloaded] | https://www.whatdotheyknow.com/request/using_a_combination_of_both_the/response/1165014/attach/html/2/FOI2018%2000360%20Leggsy.pdf.html | | 0 bytes
================================================================================
MESSAGE 1 [outgoing]
HEADER: MLeggsy
15 February 2018
Delivered
--------------------------------------------------------------------------------
Dear HM Revenue and Customs,
“Do you hold any information which would answer the following question.
Is it acceptable for a tax payer to use a combination of BOTH the "Contractor Loans Settlement Opportunity" (CLSO) for some years and the Loan Charge in 2019 for other years, in order to minimise their overall tax liability?”
Yours faithfully,
MLeggsy
================================================================================
MESSAGE 2 [incoming]
HEADER: foi.team@hmrc.gsi.gov.uk on behalf of FOI Central Team,
HM Revenue and Customs
19 February 2018
--------------------------------------------------------------------------------
Our ref: FOI2018/00360
Dear Mike Leggsy,
Freedom of Information Act 2000 Acknowledgement
Thank you for your communication of 15th 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 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
2 March 2018
--------------------------------------------------------------------------------
1 Attachment
FOI2018 00360 Leggsy.pdf
148K
View
Download
Dear Mike Leggsy,
I am writing in response to your request for information, received 15th
February.
Yours sincerely,
HMRC Freedom of Information Team
================================================================================
MESSAGE 4 [outgoing]
HEADER: MLeggsy
2 March 2018
Delivered
--------------------------------------------------------------------------------
Dear [
email address
] on behalf of FOI Central Team,
Thank for your response to my FOI request which did not directly answer my question.
Your response stated that it would depend on the tax payers specific circumstances which would indicate that it is possible to use both methods to settle contractor loan schemes.
Would you state categorically that it is allowed to use a combination of both the CLSO and 2019 Loan Charge methods to settle for some Tax payers depending on their circumstances?
Yours sincerely,
MLeggsy
================================================================================
MESSAGE 5 [outgoing]
HEADER: MLeggsy
27 May 2018
Delivered
--------------------------------------------------------------------------------
Dear [
email address
] on behalf of FOI Central Team,
Using a combination of both the CLSO and the 2019 Loan Charge.
This response is overdue.
Yours sincerely,
MLeggsy
================================================================================
MESSAGE 6 [incoming]
HEADER: HM Revenue and Customs
29 May 2018
--------------------------------------------------------------------------------
1 Attachment
FOI2018 00360 Leggsy.pdf
148K
View
Download
FOI 2018/00360
Dear Mr Leggsy,
We apologise for this late reply to your email we received on 27 May
2018. We can confirm a response to your FOI request was issued on 2
March 2018. We have attached a copy of this response for your records.
Yours sincerely
HMRC, Freedom of Information Team
show quoted sections
================================================================================
MESSAGE 7 [outgoing]
HEADER: MLeggsy
29 May 2018
Delivered
--------------------------------------------------------------------------------
Dear HM Revenue and Customs,
Thank you for your response, however I responded to this reply with a request for more detail. You acknowledged receipt of this additional question so I am somewhat surprised you have chosen to ignore that and answer the original question again.
Please answer my subsequent request.
Yours faithfully,
MLeggsy
================================================================================
MESSAGE 8 [incoming]
HEADER: HM Revenue and Customs
6 June 2018
--------------------------------------------------------------------------------
Dear Mr Leggsy,
Your reply asked the following:
“Is it acceptable for a tax payer to use a combination of BOTH the "Contractor Loans Settlement Opportunity" (CLSO) for some years and the Loan Charge in 2019 for other years, in order to minimise their overall tax liability?”
I would refer you to our original response again as it explains how to make a valid request for information. A question seeking opinion is not something we can respond to under the Freedom of Information Act.
If you want to discuss your own circumstances and settle your affairs, please contact HMRC’s Contractor Loans helpline on 03000 534 226, or email the team at [
email address
]
Yours sincerely
HMRC, Freedom of Information Team
show quoted sections
================================================================================
MESSAGE 9 [outgoing]
HEADER: MLeggsy
11 June 2018
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 'Using a combination of both the CLSO and the 2019 Loan Charge'.
I feel I have not received a straight forward answer to my request. I asked whether a combination of both CLSO and the 2019 loan charge can be used to settle tax affairs. It is clear that both can and it is possible to use both depending on individual circumstance. But this will not be confirmed. I have not asked for an opinion it is either possible to use a combination or not.
A full history of my FOI request and all correspondence is available on the Internet at this address:
https://www.whatdotheyknow.com/request/u...
Yours faithfully,
MLeggsy
================================================================================
MESSAGE 10 [incoming]
HEADER: foi.team@hmrc.gsi.gov.uk on behalf of FOI Central Team,
HM Revenue and Customs
21 June 2018
--------------------------------------------------------------------------------
Our ref: IR2018/01276
Dear Mike Leggsy,
Freedom of Information Act 2000 Acknowledgement
Thank you for your communication of 11th June 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
================================================================================
ATTACHMENT TEXT EXTRACTION / OCR
================================================================================
--------------------------------------------------------------------------------
ATTACHMENT: FOI2018_00360_Leggsy.pdf
TEXT_FILE: FOI2018_00360_Leggsy.pdf.txt
METHOD: pdf_native
OCR_USED: False
PAGES: 2
--------------------------------------------------------------------------------
--- 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
N98 1ZZ
Mike Leggsy
By email:
request-464868-02508453@whatdotheyknow.com
Email
foi.request@hmrc.gsi.gov.uk
Web
www.gov.uk
Date: 2 March 2018
Our ref:
FOI2018/00360
Dear Mr Leggsy
Freedom of Information Act 2000 (FOIA)
Thank you for your request under the FOIA, which was received on 15 February, for the
following information:
“Is it acceptable for a tax payer to use a combination of BOTH the "Contractor Loans
Settlement Opportunity" (CLSO) for some years and the Loan Charge in 2019 for other
years, in order to minimise their overall tax liability?”
Section 84 of the FOIA states that in order for a request for information to be handled as an
FOIA request, it must be for recorded information. For example, a request would be for a
copy of a policy, rather than an explanation as to why we have that policy in place. On
occasion, HMRC receives requests that do not ask for recorded information, but ask more
general questions about a policy, opinion or a decision, and that is how I am treating your
query.
The Information Commissioner has produced a reference tool to help people make effective
requests. This is published on his website at the following link: https://ico.org.uk/for-the-
public/official-information/.
If you wish to submit a clarified request by post, please send it to the address in the top right
corner of this letter. You can also submit a request by email to: foi.review@hmrc.gsi.gov.uk
Further Information
In relation to your query it may be helpful to note that the terms under which a settlement is
agreed with HMRC will depend on the taxpayer’s specific circumstances. A guide to help
you understand how you can settle your tax affairs can be found at the following link:
https://www.gov.uk/guidance/disguised-remuneration-settling-your-tax-affairs
If you would like to discuss your options or settle your affairs, please contact HMRC’s
Contractor Loans helpline on 03000 534 226, or by email at cl.resolution@hmrc.gsi.gov.uk.
If you are not satisfied with this reply you may request a review by emailing
foi.review@hmrc.gsi.gov.uk. You must request a review within 2 months of the date of this
letter. It would help us carry out our review if you set out the aspects of the reply that
concern you and why you are dissatisfied.
--- PDF page 2 ---
131427
2
If you are not content with the outcome of an internal review, you can complain to the
Information Commissioner’s Office (ICO). The ICO will not usually consider a case unless
you have exhausted the internal review procedure provided by HMRC. You can make a
complaint through the ICO’s website at: www.ico.org.uk.
Yours sincerely
Freedom of Information Team
--------------------------------------------------------------------------------
ATTACHMENT: FOI2018_00360_Leggsy_003.pdf
TEXT_FILE: FOI2018_00360_Leggsy_003.pdf.txt
METHOD: pdf_native
OCR_USED: False
PAGES: 2
--------------------------------------------------------------------------------
--- 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
N98 1ZZ
Mike Leggsy
By email:
request-464868-02508453@whatdotheyknow.com
Email
foi.request@hmrc.gsi.gov.uk
Web
www.gov.uk
Date: 2 March 2018
Our ref:
FOI2018/00360
Dear Mr Leggsy
Freedom of Information Act 2000 (FOIA)
Thank you for your request under the FOIA, which was received on 15 February, for the
following information:
“Is it acceptable for a tax payer to use a combination of BOTH the "Contractor Loans
Settlement Opportunity" (CLSO) for some years and the Loan Charge in 2019 for other
years, in order to minimise their overall tax liability?”
Section 84 of the FOIA states that in order for a request for information to be handled as an
FOIA request, it must be for recorded information. For example, a request would be for a
copy of a policy, rather than an explanation as to why we have that policy in place. On
occasion, HMRC receives requests that do not ask for recorded information, but ask more
general questions about a policy, opinion or a decision, and that is how I am treating your
query.
The Information Commissioner has produced a reference tool to help people make effective
requests. This is published on his website at the following link: https://ico.org.uk/for-the-
public/official-information/.
If you wish to submit a clarified request by post, please send it to the address in the top right
corner of this letter. You can also submit a request by email to: foi.review@hmrc.gsi.gov.uk
Further Information
In relation to your query it may be helpful to note that the terms under which a settlement is
agreed with HMRC will depend on the taxpayer’s specific circumstances. A guide to help
you understand how you can settle your tax affairs can be found at the following link:
https://www.gov.uk/guidance/disguised-remuneration-settling-your-tax-affairs
If you would like to discuss your options or settle your affairs, please contact HMRC’s
Contractor Loans helpline on 03000 534 226, or by email at cl.resolution@hmrc.gsi.gov.uk.
If you are not satisfied with this reply you may request a review by emailing
foi.review@hmrc.gsi.gov.uk. You must request a review within 2 months of the date of this
letter. It would help us carry out our review if you set out the aspects of the reply that
concern you and why you are dissatisfied.
--- PDF page 2 ---
131427
2
If you are not content with the outcome of an internal review, you can complain to the
Information Commissioner’s Office (ICO). The ICO will not usually consider a case unless
you have exhausted the internal review procedure provided by HMRC. You can make a
complaint through the ICO’s website at: www.ico.org.uk.
Yours sincerely
Freedom of Information Team