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Who recommended Ray McCann for the Loan Charge Review (appointment January 2025)

Source: WhatDoTheyKnow
Authority: HM Treasury
Status: We're waiting for Ian Heavyside (Account suspended) to read a recent response and update the status.
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SOURCE: WhatDoTheyKnow
SOURCE_URL: https://www.whatdotheyknow.com/request/who_recommended_ray_mccann_for_t
TITLE: Who recommended Ray McCann for the Loan Charge Review (appointment January 2025)
AUTHORITY: HM Treasury
AUTHORITY_URL: https://www.whatdotheyknow.com/body/hm_treasury
STATUS: We're waiting for
Ian Heavyside (Account suspended)
to read a recent response and update the status.
REQUEST_SLUG: who_recommended_ray_mccann_for_t
CAPTURED_AT: 2026-05-19T07:25:48+00:00
PROVENANCE: {"first_seen_at": "2026-05-18T12:56:30", "first_seen_page": "1", "first_query_term": "\"Loan Charge\"", "first_date_after": "2026/01/01", "first_date_before": "2027/01/01", "matched_query_terms": "\"Loan Charge\" | \"disguised remuneration\"", "matched_date_ranges": "2026/01/01 to 2027/01/01", "first_search_url_template": "https://www.whatdotheyknow.com/search/%22Loan%20Charge%22/requests?commit=Filter&query=%22Loan+Charge%22&request_date_after=2026%2F01%2F01&request_date_before=2027%2F01%2F01&request_variety%5B%5D=sent&request_variety%5B%5D=response&request_variety%5B%5D=comment&sortby=&utf8=%E2%9C%93&page="}

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MESSAGE 1 [outgoing]
HEADER: Ian Heavyside
10 January 2026
Delivered
--------------------------------------------------------------------------------
Dear HM Treasury,
Under the Freedom of Information Act 2000, please provide information identifying who (person and/or organisation) first proposed / recommended / put forward Mr Ray McCann for appointment to lead the Independent Review of the Loan Charge (commissioned January 2025).
For avoidance of doubt, I am seeking the origin of the recommendation that led to the appointment by the Exchequer Secretary to the Treasury (as stated in the published Terms of Reference), and the immediate documentary trail evidencing it.
GOV.UK
Time period: 1 October 2024 to 31 January 2025 (or from the first recorded discussion of potential candidates up to the date of appointment, if earlier/later).
Please provide:
1. Any emails, letters, messages, or written submissions to HMT (including from HMRC, external stakeholders, MPs/APPGs, campaign groups or individuals) that suggest, recommend, nominate, or propose Ray McCann for the role.
2. Any internal HMT briefings, submissions, advice notes, or ministerial submissions that record who suggested Ray McCann, or that list him among proposed candidates (including any “options” or shortlist documents).
3. Any meeting notes / minutes / call notes where Ray McCann’s appointment is discussed and the source of his nomination is recorded.
4. Any due diligence / independence assessment undertaken by HMT in relation to appointing Mr McCann (for example: conflict of interest checks, independence considerations, risk logs, or mitigation plans), insofar as they relate to the appointment decision and do not require disclosure of sensitive personal data.
Format / scope to avoid section 12:
– Please search the accounts/files of the Exchequer Secretary’s private office, the relevant directorate(s) leading the review, and the central FOI mailbox (electronic records only).
– I am content to receive redacted copies.
– If identifying an individual would engage section 40, please instead provide the identity of the organisation (or the role/capacity, e.g., “Loan Charge campaign group representative / APPG officer / named MP”), and confirm whether the recommendation came from (a) a Loan Charge campaign group, (b) an MP/peer, (c) a professional body, (d) HMRC, or (e) another source.
Public interest context:
The independence of the review leader is central to public confidence. Ministers have stated in Parliament that Mr McCann’s name was suggested by “one of the Loan Charge campaigners”, so there is a clear, recorded public claim about the source of the recommendation.
If any part of this request is refused, please provide the reasoning and consider partial disclosure of the remainder.
Yours faithfully,
Ian Heavyside

================================================================================
MESSAGE 2 [incoming]
HEADER: FOI Requests,
        HM Treasury
9 February 2026
--------------------------------------------------------------------------------
Dear Ian Heavyside,
Thank you for your enquiry of 12th January, requesting:
"Under the Freedom of Information Act 2000, please provide information
identifying who (person and/or organisation) first proposed / recommended
/ put forward Mr Ray McCann for appointment to lead the Independent Review
of the Loan Charge (commissioned January 2025).
For avoidance of doubt, I am seeking the origin of the recommendation that
led to the appointment by the Exchequer Secretary to the Treasury (as
stated in the published Terms of Reference), and the immediate documentary
trail evidencing it.
GOV.UK
Time period: 1 October 2024 to 31 January 2025 (or from the first recorded
discussion of potential candidates up to the date of appointment, if
earlier/later).
Please provide:
1. Any emails, letters, messages, or written submissions to HMT (including
from HMRC, external stakeholders, MPs/APPGs, campaign groups or
individuals) that suggest, recommend, nominate, or propose Ray McCann for
the role.
2. Any internal HMT briefings, submissions, advice notes, or ministerial
submissions that record who suggested Ray McCann, or that list him among
proposed candidates (including any "options" or shortlist documents).
3. Any meeting notes / minutes / call notes where Ray McCann's appointment
is discussed and the source of his nomination is recorded.
4. Any due diligence / independence assessment undertaken by HMT in
relation to appointing Mr McCann (for example: conflict of interest
checks, independence considerations, risk logs, or mitigation plans),
insofar as they relate to the appointment decision and do not require
disclosure of sensitive personal data.
Format / scope to avoid section 12:
- Please search the accounts/files of the Exchequer Secretary's private
office, the relevant directorate(s) leading the review, and the central
FOI mailbox (electronic records only).
- I am content to receive redacted copies.
- If identifying an individual would engage section 40, please instead
provide the identity of the organisation (or the role/capacity, e.g.,
"Loan Charge campaign group representative / APPG officer / named MP"),
and confirm whether the recommendation came from (a) a Loan Charge
campaign group, (b) an MP/peer, (c) a professional body, (d) HMRC, or (e)
another source.
Public interest context:
The independence of the review leader is central to public confidence.
Ministers have stated in Parliament that Mr McCann's name was suggested by
"one of the Loan Charge campaigners", so there is a clear, recorded public
claim about the source of the recommendation.
If any part of this request is refused, please provide the reasoning and
consider partial disclosure of the remainder."
Following a search of our records, we can confirm that HM Treasury does
hold information within the scope of your request.
We have identified information that falls within the scope of your
request, which we believe engages the following exemption: Section
35(1)(d) - operation of a ministerial private office.
This is a qualified exemption, and we are required to balance the public
interest between disclosure and non-disclosure. By virtue of section 10(3)
of the FOI Act, where public authorities have to consider the balance of
the public interest in relation to a request, they do not have to comply
with the request until such time as is reasonable in the circumstances.
We always aim to reply to requests in full within twenty working days,
even when the balancing of the public interest is required; however, in
this case, the Treasury has not yet resolved the different considerations.
We therefore need to take some additional time to assess whether the
public interest in withholding the information outweighs the public
interest in disclosing it.
We estimate that it will take us another 20 working days to complete our
consideration, although we will of course reply sooner if possible.
Yours sincerely,
Freedom of Information Team | HM Treasury, 1 Horse Guards Road, London,
SW1A 2HQ | [1]www.gov.uk/hm-treasury
References
Visible links
1.
http://www.gov.uk/hm-treasury

================================================================================
MESSAGE 3 [incoming]
HEADER: FOI Requests,
        HM Treasury
14 May 2026
--------------------------------------------------------------------------------
2 Attachments
FOI2026 00690.pdf
152K
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Download
Annex FOI2026 00690.pdf
295K
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Dear Ian Heavyside,
Please find attached a response to your recent FOI request.
Yours sincerely,
Freedom of Information Team | HM Treasury, 1 Horse Guards Road, London,
SW1A 2HQ | [1]www.gov.uk/hm-treasury
References
Visible links
1.
http://www.gov.uk/hm-treasury

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ATTACHMENT TEXT EXTRACTION / OCR
================================================================================

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ATTACHMENT: Annex_FOI2026_00690.pdf
TEXT_FILE: Annex_FOI2026_00690.pdf.txt
METHOD: pdf_native
OCR_USED: False
PAGES: 13
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--- PDF page 1 ---
Annex – FOI2026/00690 
Email 1: Readout 
From: [redacted, s40]] 
Sent on: Wednesday, July 24, 2024 09:01:24 AM 
To: XST – HMT <XST [redacted, s35(1)(d)]] 
CC: [redacted, s40]] 
Subject: Loan Charge Engagement Session Readout 
Hi, 
 Sending this internally in the office to keep as a record. 
Thanks, 
[redacted, s40]] 
Time: 9:30-10:15am 
Attendees: 
In person: XST, Spencer Thompson, XST PS, [redacted, s40]], [redacted, s40]], [redacted, s40]], 
[redacted, s40] Greg Smith (MP and recent chair of Loan Charge APPG) 
Dial-in: [redacted, s40], [redacted, s40] 
Readout: 
• 
XST introduced himself and led a round of introductions. He set out that he wanted to 
move quickly. Attendees briefly set out their backgrounds and headlines views. 
• 
XST set out the context that he became aware of this issue in opposition and that the 
Chancellor is interested. He explained that he hadn’t commissioned HMT/HMRC to do 
any substantive analysis yet, as he wanted to listen to this group of stakeholders first. 
He stressed that he couldn’t make any commitments today and that he was here to 
listen. 
• 
[redacted, s40] presented him with LCAG’s review proposals. He noted ways this could 
fit into wider government work around workers’ rights and candour duty. 
• 
XST set out his initial personal thoughts. He stressed that any new review should 
command respect and be seen as the right way forward. He set out the points he was 
considering exploring via the review. 
o 
Safeguards against self-harm 
o 
The role of promoters 
o 
The situation of people facing particularly large bills 
o 
HMRC’s historic approach to DR schemes that led to the loan charge

--- PDF page 2 ---
o 
HMRC’s approach to administering the loan charge 
o 
Fairness for all taxpayers and care for the public finances 
o 
Reaching a solution 
o 
Avoiding this situation in the future 
• 
There was a discussion as to whether the report should be purely backwards-looking or 
look forward too. GS advocated for a review that only looked at the retrospective issues 
with the LC. [redacted, s40] suggested that it be forward looking too and include wider 
reforms e.g., defining what an umbrella company is. [redacted, s40] felt that being 
forwards-looking would be too broad and the immediate priority should be getting lives 
back on track. 
• 
[redacted, s40] spoke through the human impact of the loan charge in terms of family 
breakdown and loss of homes, leading to this policy being more expensive for the state 
even accounting for extra tax raised. 
• 
[redacted, s40] argued that most of those affected by the LC did not have the objective 
of avoiding tax and that they used these agencies because of efficiency gains. 
• 
[redacted, s40] raised concerns about 684(7A)(b) notices. 
• 
XST explained that he wanted to now discuss practical considerations around a 
potential review. [redacted, s40] suggested [redacted, s40], [redacted, s40], Ray 
McCann, [redacted, s40], and [redacted, s40] as potential chairs. [redacted, s40] 
suggested the main merit of these individuals was that they had a tax/law background 
without having been involved in the schemes. 
• 
There was a brief discussion of the previous Morse review and criticisms of it. In 
particular, stakeholders felt it wasn’t fully independent and felt that it was constrained 
by its terms of reference. 
• 
GS explained that there was significant cross-party support for action against the Loan 
Charge. 
• 
GS suggested that a political decision needed to be taken on the principle of 
retrospective policies before entering into any reviews. He also flagged that he felt there 
was a risk this could be the new Horizon scandal. 
• 
XST asked for views on how to utilise himself, his chair or chairs, and the Civil Service. 
He stressed that there would need to be some official involvement. XST also stressed 
that he was keen to make progress but didn’t want to move too quickly. 
• 
GS asked if XST was willing to speak to those affected by the LC. XST said he went into 
politics in order to listen to people.

--- PDF page 3 ---
From: [redacted, s40]] 
Sent: Tuesday, August 13, 2024 3:17:15 PM 
To: XST - HMT [redacted, s35(1)(d)] 
CC: [redacted, s40]] 
Subject: Ray McCann meeting readout 
Hi there, 
I’m sending this to the office mailbox as a record. 
XST met with Ray McCann on Thursday, 8 August, on teams. XST and Ray discussed the Loan 
Charge, including the historic policy and potential routes towards a solution for those who have 
not settled. XST raised the possibility of Ray chairing a potential review in the future, and Ray 
indicated he would be willing to do so. 
 
Thanks, 
[redacted, s40]] 
 
 
[redacted, s40]] | Assistant Private Secretary to the Exchequer Secretary to the 
Treasury 
[redacted, s40]] 1 Horse Guards Road, London, SW1A 2HQ 
Mobile: [redacted, s40]] | www.gov.uk/hm-treasury |

--- PDF page 4 ---
Submission: Loan Charge Review – Potential Reviewer 
 
Summary: 
You are minded to ask Ray McCann to undertake a further independent review of the Loan 
Charge. This note sets out Mr. McCann’s professional background and previous history with the 
Loan Charge and disguised remuneration. We are not offering a view or recommendation on any 
reviewer. Ray McCann is an experienced and respected tax professional with experience in both 
the private sector and with HMRC. During his time as CIOT President and more recently, Mr. 
McCann has been publicly involved in the Loan Charge debate. 
Loan Charge Review 
You have indicated that you are minded to ask Ray McCann to undertake a further independent 
review of the Loan Charge. To ensure you are in full possession of the facts, this note sets out 
Mr. McCann’s professional background and previous history with the Loan Charge and 
disguised remuneration. We are not offering a view or recommendation on any reviewer. 
Mr. McCann has nearly 50 years’ experience as a tax professional and is respected across the 
tax industry. He currently acts as a consultant for Joseph Hage Aaronson LLP, having retired as a 
partner in 2020. Mr. McCann is a fellow of the Chartered Institute of Taxation and acted as 
President of CIOT from 2018 until 2019. Prior to taking up his role at JHA, he held senior 
positions with PwC, Pinsent Masons and HMRC1. 
Before moving to PwC in 2006, Mr. McCann worked for the Inland Revenue/HMRC for 31 years. 
During his time with HMRC, he worked as an Inspector of Taxes in various compliance roles and 
was latterly a Deputy Director in HMRC’s Anti-Avoidance Group (AAG) (the predecessor to the 
current Counter Avoidance directorate)2. 
During his time in AAG, Mr. McCann was directly involved in HMRC’s activity to counter the use 
of disguised remuneration schemes, including leading on the development and implementation 
of the Disclosure of Tax Avoidance Scheme (DOTAS) rules that require promoters of tax 
avoidance schemes to notify HMRC of their schemes3. You should note the risk that this creates 
a perceived conflict of interest, particularly if the scope of the review requires a reviewer to 
consider HMRC’s historical role in tackling disguised remuneration prior to the introduction of 
the Loan Charge. 
In their letter4 to the Prime Minister (in his then position of Leader of the Opposition) during the 
General Election period, the Loan Charge Action Group set out their asks for a ‘genuinely 
independent review’. These included that “The reviewer/head of the inquiry must not be 
appointed by Government (Treasury and HMRC) and they must have no input into candidates or 
candidate selection. The APPG has previously suggested a tax judge, but whoever it is it must be 
someone with no links to HMRC or Government, past or present.”

--- PDF page 5 ---
So, you should note that Mr. McCann does not meet LCAG’s stated criteria for a suitable 
reviewer. 
During his time as CIOT President and more recently, Mr. McCann has been publicly involved in 
the Loan Charge debate and has engaged extensively with campaigners on social media. Many 
of these exchanges with campaigners, dating back to 2018, can still be found on X5. Although 
Mr. McCann’s position (particularly more recently) is not uncritical of HMRC and the Loan 
Charge as a policy, you should note that he has been attacked by some campaigners for 
allegedly being too close to HMRC officials and for his involvement in the development of 
DOTAS6. 
You should also be aware Mr. McCann has publicly signed a proposal by the "Loan Charge 
Resolution Group" (LCRG) which sets out recommended solutions to the matter - see 
here: Proposal – Loan Charge Resolutions.7 
Mr. McCann’s employment with HMRC ended over 18 years ago and he has been publicly 
critical of HMRC on a number of occasions. His employment history is also a matter of public 
record, with references in multiple news article and his social media profiles. It is also not 
unusual for tax professionals in the private sector to have worked, at some point in their careers, 
for HMRC, and several of the tax professionals (such as [redacted, s40] who have provided 
support to the campaigners have also previously worked for HMRC.

--- PDF page 6 ---
Email chain 3: 
Email 1: 
From: [redacted, s40] 
Sent: Thursday, November 14, 2024 2:37:05 PM 
To [redacted, s40]] Thompson, Spencer - HMT; Thomas, Rhodri - HMT [redacted, s40]] 
Cc: Webster, Laura – HMT; Halls, Jonny - HMT [redacted, s40] ; [redacted, s40] 
Subject: [For clearance:] Due diligence on XST's preferred reviewer for the Independent Review 
of the Loan Charge 
Hi all, 
At Budget, the government announced that it would commission a further independent review 
of the Loan Charge. XST would like to appoint Ray McCann as the lead reviewer. 
Clearance request 
No10 need to clear XST’s preferred candidate. As part of that, HMT SpAds are required to clear 
the appointment (after receiving a due diligence note from officials) and clear the proforma for 
No10 (which summarises that due diligence). Both of which can be found here: 
• 
Due diligence note: 
 RM - due diligence.docx 
• 
No10 proforma: 
 No 10 - Direct Appointments Pro Forma - LC Review.docx 
Process: 
Following this, we will submit the proforma to No10. They typically accept proformas on 
Monday morning for a readout the following Monday. 
Once we have clearance from No10, the candidate will be issued with a declaration-of-interest 
form that he will be required to return before appointment. This will be scrutinised by senior 
officials and, should it be considered necessary by those officials, the Permanent Secretary. 
The candidate will then be issued with an appointment letter that sets out the terms of his 
appointment. This covers things like the length of appointment and remuneration/expenses but 
also any mitigations that might be judged necessary following the return of his declaration-of-
interests form. 
Let me know if you have any questions on the above. 
Best, 
[redacted, s40] 
[redacted, s40] | Personal Tax, Welfare and Pensions | 
HM Treasury, 1 Horse Guards Road, London, SW1A 2HQ | [redacted, s40] | www.gov.uk/hm-
treasury

--- PDF page 7 ---
Email chain 3: 
Attachment 1: RM – due diligence note 
 
Due diligence note on XST’s preferred candidate for the Loan Charge Review 
Introduction 
1. At Autumn Budget 2024, the government announced that it would commission a further 
independent review of the Loan Charge. XST would like to appoint Ray McCann as the 
lead reviewer. 
2. This note sets out Mr. McCann’s professional background and previous history with the 
Loan Charge and disguised remuneration. It summarises what has been found in 
conducting due diligence checks of Mr. McCann. Earlier in the process, we provided a 
background note to XST which covered similar material. 
3. This note does not cover what Mr. McCann may declare on his declarations-of-interest 
form, which will be issued to him shortly and scrutinised by senior officials in the normal 
way. 
Experience 
4. Mr. McCann has nearly 50 years’ experience as a tax professional and is respected 
across the tax industry. He currently acts as a consultant for Joseph Hage Aaronson 
LLP (JHA), having retired as a partner in 2020. Mr. McCann is a fellow of the Chartered 
Institute of Taxation (CIOT) and acted as President of CIOT from 2018 until 2019. Prior to 
taking up his role at JHA, he held senior positions with PwC, Pinsent Masons 
and HMRC.1 
5. Before moving to PwC in 2006, Mr. McCann worked for the Inland Revenue/HMRC for 31 
years. During his time with HMRC, he worked as an Inspector of Taxes in various 
compliance roles and was latterly a Deputy Director in HMRC’s Anti-Avoidance Group 
(AAG) (the predecessor to the current Counter Avoidance directorate).2 
6. During his time in AAG, Mr. McCann was directly involved in HMRC’s activity to counter 
the use of disguised remuneration schemes, including leading on the development and 
implementation of the Disclosure of Tax Avoidance Scheme (DOTAS) rules that require 
promoters of tax avoidance schemes to notify HMRC of their schemes.3 
Perceived and possible conflicts 
Former employee of HMRC 
7. You should note the risk that Mr McCann’s time in HMRC creates a perceived conflict of 
interest, though this is mitigated by the fact that the review focuses only on the Loan 
Charge which was introduced after Mr. McCann left HMRC. 
8. In their letter4 to the Prime Minister (in his then position of Leader of the Opposition) 
during the General Election period, the Loan Charge Action Group (LCAG) set out their 
asks for a ‘genuinely independent review’. These included that “The reviewer/head of the 
inquiry must not be appointed by Government (Treasury and HMRC) and they must have

--- PDF page 8 ---
no input into candidates or candidate selection. The APPG has previously suggested a 
tax judge, but whoever it is it must be someone with no links to HMRC or Government, 
past or present.” 
9. You should therefore note that Mr. McCann does not meet LCAG’s stated criteria for a 
suitable reviewer, although we understand Mr McCann was recommended to XST during 
a meeting with campaigners. 
10. Mr. McCann’s employment with HMRC ended over 18 years ago and he has been 
publicly critical of HMRC on a number of occasions. His employment history is also a 
matter of public record, with references in multiple news article and his social media 
profiles. It is not unusual for tax professionals in the private sector to have worked, at 
some point in their careers, for HMRC, and several of the tax professionals (such as 
Keith Gordon5) who have provided support to the campaigners have also previously 
worked for HMRC. 
Public comments on the Loan Charge and disguised remuneration 
11. During his time as CIOT President and more recently, Mr. McCann has been publicly 
involved in the Loan Charge debate and has engaged extensively with campaigners on 
social media. Many of these exchanges with campaigners, dating back to 2018, can still 
be found on X.6 Although Mr. McCann’s position (particularly more recently) is not 
uncritical of HMRC and the Loan Charge as a policy, you should note that he has been 
attacked by some campaigners for allegedly being too close to HMRC officials and for 
his involvement in the development of DOTAS.7 
12. Mr McCann has had articles published on the Loan Charge that can still be found 
online.8 He also gave evidence to the Treasury Select Committee (TSC) on “The conduct 
of tax enquiries and resolution of tax disputes” during his time as CIOT president.9 In his 
evidence session, the Loan Charge was discussed extensively. 
13. You should also be aware that Mr. McCann publicly signed a proposal by the "Loan 
Charge Resolution Group" (LCRG) which sets out recommended solutions to the matter 
- see here: Proposal – Loan Charge Resolutions.10 
14. It is not surprising that someone with expertise, experience and respect across the tax 
industry has engaged on a policy that has received significant attention since it was 
announced. His engagement and understanding of the issue is, in many respects, a 
benefit in that he brings genuine expertise to the review and understands many of the 
concerns raised. However, his commentary and engagement on this issue are likely to 
be scrutinised carefully following his appointment and may be used by those unsatisfied 
by the review in an attempt to undermine Mr McCann, his review and/or its 
recommendations. For example, while his evidence to the TSC in 2018 was reasonably 
even-handed and not uncritical of the Loan Charge policy and HMRC, he did say: “It is 
quite a challenge for someone who has any knowledge and experience of these 
arrangements [loan schemes] to look at this with great sympathy.” Although he goes on 
to say: “However, I am sympathetic to the situation that a lot of people end up in.” 
Public support of governing party 
15. Mr. McCann has publicly (mainly via his X account)11 defended the current government 
and criticised the opposition (both since they have been in opposition and when they

--- PDF page 9 ---
were in government). He has done so on a range of issues including, for 
example: immigration, standards in public life, and most recently in relation 
to measures announced at Budget. Some of this commentary is also present on his 
LinkedIn profile. 
16. Before Mr. McCann is appointed, we would suggest that it be made clear to him that he 
should cease political commentary on his social media channels while the review is 
taking place. 
Methods 
17. Mr. McCann’s experience and engagement on the Loan Charge is a well-established 
matter of public record. We have used internet searches and ran searches of his social 
media (mainly X but also LinkedIn) to gather the evidence presented above. All of what 
we have presented could be found by a member of the public. The searches have been 
conducted manually and so it is likely that we have not uncovered everything. 
18. Searches via the Electoral Commission website have been conducted. We have not 
found any evidence that Mr. McCann has personally donated to a political party. 
19. As normal, a declarations-of-interest form will be issued to Mr. McCann and be returned 
before he is appointed. Should anything of concern beyond that noted above be made 
known to us, this will be dealt with in the usual way. 
 
Email chain 3: 
Attachment 2: No 10 Direct Appointments Pro Forma 
 
Direct Appointments Pro Forma 
 
Information required by No10: 
Department to complete: 
Body & Department Name 
Responsible Minister Name 
 
Independent Review of the Loan Charge 
HM Treasury 
Exchequer Secretary to the Treasury 
Role(s) 
 
Overview of the role 
responsibilities 
 
 
Lead Reviewer of the Independent Review of the Loan Charge. 
 
The reviewer will need to consider in detail the policy of the Loan 
Charge. The review is expected to focus on the barriers 
preventing those subject to the Loan Charge from reaching 
resolution with HMRC and consider how they could be 
encouraged to do so. Further details on what the review will cover 
can be found in the review’s draft terms of reference.

--- PDF page 10 ---
The role will involve engaging with a range of stakeholders, 
including those affected by the Loan Charge, campaigners, tax 
policy experts, government officials, and ministers. 
The reviewer will need to submit a report upon the review’s 
conclusion and is expected to make recommendations to 
government. 
Proposed term length and 
start date 
 
3 months from January 2025 
Criteria against which 
candidates have been 
considered 
The appointment process has been led by the minister. He 
has indicated that his preference is based on the proposed 
candidate’s experience, understanding of the issue, and respect 
across the tax industry. Officials agree that the proposed 
candidate meets these criteria. 
Diversity data of proposed 
candidates 
[redacted, s40] 
Location of proposed 
candidate(s) 
[redacted, s40] 
 
Proposed 
Candidate Name(s) 
Candidate Bios 
Due Diligence Summary 
 
Ray McCann 
 
 
 
Mr McCann has nearly 
50 years’ experience as a tax 
professional and is respected 
across the tax industry. He 
currently acts as a consultant 
for Joseph Hage Aaronson 
LLP (JHA), having retired as a 
partner in 2020. Mr. McCann is 
a fellow of the Chartered 
Institute of Taxation (CIOT) and 
acted as President of CIOT 
from 2018 until 2019. Prior to 
taking up his role at JHA, he 
held senior positions with 
PwC, Pinsent Masons and 
HMRC. 
We have identified three key sources of potential 
perceived conflicts, namely: 
• 
Previous work for HMRC: Some 
campaigners on this issue have said the 
reviewer should have no links to HMRC, 
although Mr McCann was recommended 
as a potential reviewer to XST during a 
meeting with campaigners and Mr McCann 
left HMRC more than 18 years ago. 
• 
Public comments on the policy 
area: Mr McCann has engaged extensively 
on this subject. This is, in many respects, a 
benefit given the expertise and experience 
he will bring to the role. But it also carries 
risk. For example, his past comments 
could be used by those who do not agree 
with the outcome of the review to 
undermine the reviewer, his review, or its 
recommendations.

--- PDF page 11 ---
• 
Public support for the governing 
party: Mr McCann has criticised the 
Conservative Party on social media, both 
when they were in government and since 
they have been in opposition. He has also 
supported the current government on 
certain issues, including measures 
recently announced at Budget. We would 
encourage Mr McCann to cease all 
political commentary during the review 
period. 
 
Searches via the Electoral Commission website 
have been conducted. We have not found any 
evidence that Mr McCann has personally donated 
to a political party. 
Other Candidates 
Considered 
Candidate Bios 
Due Diligence Summary 
[redacted, s40] 
[redacted, s40] 
[redacted, s40]

--- PDF page 12 ---
Submission 2: Ray McCann Conflict of Interest Form 
 
DECLARATION OF INTERESTS – Self Declaration. 
 
Independent Review of the Loan Charge 
 
Applicant name: Ray McCann 
 
[redacted, s40]

--- PDF page 13 ---
Email Chain 4 
From: [redacted, s s40]] 
Sent on: Wednesday, January 22, 2025 12:05:24 AM 
To: XST - HMT [redacted, s40]] 
Subject: 
 Ray-XST Meeting 5 September 
Hi – sending this to the office as a formal record. 
Ray and the XST met on 5 September 2024 from 1100-1130 AM. 
Readout: 
• 
XST referenced his meeting of 27 August that Greg Smith and LCAG facilitated where XST 
met with and heard the testimonies of those affected by the Loan Charge, and how 
powerfully affected by this XST was. 
• 
XST then set out his objectives for the Loan Charge review, which were focused around 
bringing the matter to a close for affected individuals. These sat in tandem with an 
objective to put individuals’ wellbeing at the forefront of a solution, and being fair to all 
taxpayers (including both those who have already settled, and the wider taxpaying 
population). 
• 
Ray felt these objectives were appropriate. Ray felt that there should no question that at 
least some tax was due, but equally that the Loan Charge process created by HMRC had 
not led to a positive outcome for individuals affected, HMRC, and wider taxpayers. Ray’s 
view was that looking better at how individuals could be incentivised to pay, even if that 
meant reducing liabilities, would achieve XST’s objectives. 
• 
XST formally asked Ray to undertake the Loan Charge review, and Ray agreed. 
 
 
[redacted, s40]] | Assistant Private Secretary to the Exchequer Secretary to the 
Treasury 
[redacted, s40]] ,1 Horse Guards Road, London, SW1A 2HQ 
Mobile: [redacted, s40]] www.gov.uk/hm-treasury |

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ATTACHMENT: FOI2026_00690.pdf
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HM Treasury 
1 Horse Guards Road 
London 
SW1A 2HQ 
 
 
 
 
 
 
 
 
020 7270 5000 
foirequests@hmtreasury.gov.uk 
www.gov.uk/hm-treasury 
 
14 May 2026 
 
Ref: FOI2026/00690 
Dear Requester, 
 
Freedom of Information Act 2000 
 
Thank you for your enquiry of 10 January 2026, which we have considered under the 
terms of the Freedom of Information Act 2000 (the FOI Act). 
 
You asked for the following information: 
 
Under the Freedom of Information Act 2000, please provide information 
identifying who (person and/or organisation) first proposed / recommended / 
put forward Mr Ray McCann for appointment to lead the Independent Review 
of the Loan Charge (commissioned January 2025). 
 
For avoidance of doubt, I am seeking the origin of the recommendation that 
led to the appointment by the Exchequer Secretary to the Treasury (as stated 
in the published Terms of Reference), and the immediate documentary trail 
evidencing it. 
GOV.UK 
 
Time period: 1 October 2024 to 31 January 2025 (or from the first recorded 
discussion of potential candidates up to the date of appointment, if 
earlier/later). 
 
Please provide: 
 
1. Any emails, letters, messages, or written submissions to HMT (including 
from HMRC, external stakeholders, MPs/APPGs, campaign groups or 
individuals) that suggest, recommend, nominate, or propose Ray McCann for 
the role. 
 
2. Any internal HMT briefings, submissions, advice notes, or ministerial 
submissions that record who suggested Ray McCann, or that list him among 
proposed candidates (including any "options" or shortlist documents). 
 
3. Any meeting notes / minutes / call notes where Ray McCann's appointment 
is discussed and the source of his nomination is recorded. 
 
4. Any due diligence / independence assessment undertaken by HMT in 
relation to appointing Mr McCann (for example: conflict of interest checks, 
independence considerations, risk logs, or mitigation plans), insofar as they 
relate to the appointment decision and do not require disclosure of sensitive 
personal data.

--- PDF page 2 ---
Format / scope to avoid section 12: 
- Please search the accounts/files of the Exchequer Secretary's private office, 
the relevant directorate(s) leading the review, and the central FOI mailbox 
(electronic records only). 
- I am content to receive redacted copies. 
- If identifying an individual would engage section 40, please instead provide 
the identity of the organisation (or the role/capacity, e.g., "Loan Charge 
campaign group representative / APPG officer / named MP"), and confirm 
whether the recommendation came from (a) a Loan Charge campaign group, 
(b) an MP/peer, (c) a professional body, (d) HMRC, or (e) another source. 
 
Public interest context: 
The independence of the review leader is central to public confidence. 
Ministers have stated in Parliament that Mr McCann's name was suggested 
by "one of the Loan Charge campaigners", so there is a clear, recorded public 
claim about the source of the recommendation. 
 
If any part of this request is refused, please provide the reasoning and 
consider partial disclosure of the remainder. 
 
Following a search of our records, we can confirm that HM Treasury does hold 
information within the scope of your request. 
 
Please find attached a document outlining the information in scope of your request. 
 
We are withholding some information under the following sections of the FOI Act: 
 
Section 35(1)(d) - Ministerial Private Office 
 
We consider that some of the information you have requested engages the 
exemption provided by section 35(1)(d) of the FOI Act, which protects information 
related to the administration of a Ministerial private office. This is because it relates 
to the email addresses used by a private office. Section 35 is a qualified exemption, 
and we have considered whether the balance of the public interest favours disclosing 
or withholding this information. 
 
There is a public interest in the Government being open and transparent, however 
the department has set processes in place for members of the public to make 
requests for information and general enquiries. Releasing private office emails would 
allow others to circumvent these processes and cause disruption to the operation of 
private offices and the department. We deem the public interest lies in withholding 
this information. 
 
Section 40 
 
Section 40(2) of the FOI Act, by virtue of section 40(3)(a)(i) provides an absolute 
exemption for personal data which then falls to be dealt with under the UK General 
Data Protection Regulation (UKGDPR) and the Data Protection Act 2018. Personal 
data of third parties can only be disclosed in accordance with the data protection 
principles. In particular, the first data protection principle requires that disclosure 
must be lawful and fair and must comply with one of the conditions in Article 6 of the 
UKGDPR.

--- PDF page 3 ---
If you have any queries about this letter, please contact us. Please quote the 
reference number above in any future communications. 
 
Yours sincerely, 
 
HM Treasury

--- PDF page 4 ---
Copyright notice 
 
Most documents HM Treasury supplies in response to a Freedom of Information 
request, including this letter, continue to be protected by Crown copyright. This is 
because they will have been produced by Government officials as part of their work. 
You are free to use these documents for your information, for any non-commercial 
research you may be doing and for news reporting. Any other re-use, for example 
commercial publication, will require the permission of the copyright holder. Crown 
copyright is managed by The National Archives and you can find details on the 
arrangements for re-using Crown copyright material at: 
http://www.nationalarchives.gov.uk/information-management/re-using-public-sector-
information/uk-government-licensing-framework/crown-copyright/ 
Your right to complain under the Freedom of Information Act 2000 
If you are not happy with this reply, you can request a review by writing to HM 
Treasury at 1 Horse Guards Road, London, SW1A 2HQ, or by emailing us at the 
address below. Any review request must be made within 40 working days of the date 
of this letter. 
Email: foirequests@hmtreasury.gov.uk 
 
It would assist our review if you set out which aspects of the reply concern you and 
why you are dissatisfied. 
 
If you are not content with the outcome of the review, you may apply directly to the 
Information Commissioner for a decision. Generally, the Commissioner will not make 
a decision unless you have exhausted the complaints procedure provided by HM 
Treasury which is outlined above. 
The Information Commissioner can be contacted at: The Information 
Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF 
(or via their website at: https://ico.org.uk ).