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What is the average period of time that enquiries have been open for protected years Years related to the so called "Loan Schemes / Disguised Remuneration

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

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SOURCE: WhatDoTheyKnow
SOURCE_URL: https://www.whatdotheyknow.com/request/what_is_the_average_period_of_ti
TITLE: What is the average period of time that enquiries have been open for protected years Years related to the so called "Loan Schemes / Disguised Remuneration
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: what_is_the_average_period_of_ti
CAPTURED_AT: 2026-05-19T07:24:25+00:00
PROVENANCE: {"first_seen_at": "2026-05-18T12:58:02", "first_seen_page": "1", "first_query_term": "\"disguised remuneration\"", "first_date_after": "2018/01/01", "first_date_before": "2019/01/01", "matched_query_terms": "\"disguised remuneration\"", "matched_date_ranges": "2018/01/01 to 2019/01/01", "first_search_url_template": "https://www.whatdotheyknow.com/search/%22disguised%20remuneration%22/requests?commit=Filter&query=%22disguised+remuneration%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_01390_Final.pdf | https://www.whatdotheyknow.com/request/what_is_the_average_period_of_ti/response/1198927/attach/2/FOI2018%2001390%20Final.pdf?cookie_passthrough=1 | application/pdf | 382183 bytes
- [not downloaded] | https://www.whatdotheyknow.com/request/what_is_the_average_period_of_ti/response/1198927/attach/html/2/FOI2018%2001390%20Final.pdf.html |  | 0 bytes

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MESSAGE 1 [outgoing]
HEADER: Gary Tinker
1 July 2018
Delivered
--------------------------------------------------------------------------------
Dear HM Revenue and Customs,
Many thousands of people now have open enquiries related to the Loan Schemes that are described by yourselves as disguised remuneration.  These can go back as far as 1999.
What is the average period of time that an enquiry has remained open for protected years?
Yours faithfully,
Gary Tinker

================================================================================
MESSAGE 2 [incoming]
HEADER: foi.team@hmrc.gsi.gov.uk on behalf of FOI Central Team,
        HM Revenue and Customs
2 July 2018
--------------------------------------------------------------------------------
Our ref: FOI2018/01390
Dear Mr Tinker,
Freedom of Information Act 2000 Acknowledgement
Thank you for your communication of 1st July 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
30 July 2018
--------------------------------------------------------------------------------
1 Attachment
FOI2018 01390 Final.pdf
373K
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Dear Mr Tinker,
I am writing in response to your request for information, received 1st
July 2018.
Yours sincerely,
HMRC Freedom of Information Team

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ATTACHMENT TEXT EXTRACTION / OCR
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ATTACHMENT: FOI2018_01390_Final.pdf
TEXT_FILE: FOI2018_01390_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 Gary Tinker 
By email: request-495039-
2a68339a@whatdotheyknow.com 
 
Email 
foi.request@hmrc.gsi.gov.uk 
Web 
www.gov.uk 
Date: 30 July 2018 
 
Our ref: 
FOI2018/01390 
 
 
Dear Mr Tinker 
 
Freedom of Information Act 2000 (FOIA) 
 
Thank you for your request, which was received on 1 July, for the following information: 
 
“Many thousands of people now have open enquiries related to the Loan Schemes that are 
described by yourselves as disguised remuneration. These can go back as far as 1999. 
What is the average period of time that an enquiry has remained open for protected years?” 
 
I can confirm HMRC holds information that falls within the scope of your request. However, 
we estimate that it would exceed the FOIA cost limit to deal with it. The cost limit, which is 
specified in regulations, equates to one person spending 3½ working days locating and 
extracting all of the information within scope of the request. 
 
Although HMRC holds information about the number of enquiries made in respect of 
‘Disguised Remunerations’ (DR) schemes, to provide information regarding the average 
period of time an enquiry case has remained open would require us to identify and cross 
check DR cases across multiple HMRC IT systems and business streams and in some 
instances manually review records at individual case level to establish when an enquiry was 
first opened, closed or whether it is still ongoing. To conduct this work would exceed the 
amount as specified in legislation. 
 
Normally, HMRC would explore with you how you might be able to narrow or refine your 
request so that it did not exceed the FOIA cost limit. However, in this case, I cannot see any 
scope for doing this. Even narrowing your request to one particular year would still exceed 
the costs limit. 
 
I have established that the time necessary to complete this task would exceed the cost limit 
by some way. Consequently, under section 12(1) of the FOIA, HMRC is not obliged to 
comply with your request and we will not be processing it further. 
 
To be helpful, and outside of the Act, you might like to know that enquiries into DR tax 
avoidance cases can be time consuming and take several years because of the very 
complex nature of the arrangements. We also rely on the cooperation of scheme users to 
provide information and agree to pay the tax they owe.

--- PDF page 2 ---
2 
You might like to be aware that on 7 November 2017 ‘Disguised Remuneration: detailed 
settlement terms’ were published on GOV.UK and more recently a ‘HMRC issue briefing: 
disguised remuneration charge on loans’ on 18 July 2018. These are available at: 
 
www.gov.uk/government/publications/disguised-remuneration-detailed-settlement-
terms/disguised-remuneration-detailed-settlement-terms 
 
 
www.gov.uk/government/publications/hmrc-issue-briefing-disguised-remuneration-
charge-on-loans/hmrc-issue-briefing-disguised-remuneration-charge-on-loans 
 
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 complain to the 
Information Commissioner’s Office. The following link explains how to do this: 
https://ico.org.uk/concerns/ 
 
 
Yours sincerely, 
 
 
Freedom of Information Team