In a 17-page letter on the loan charge to the members of the Treasury Committee, HMRC chief executive Jim Harra said that whether disguised remuneration schemes were entered into ‘unwittingly’ this would not affect HMRC’s decision to pursue the unpaid tax as the schemes were ‘contrived tax avoidance’.

He stressed that ‘the motives of those engaging in tax avoidance schemes do not affect whether tax is due’.

‘We recognise that people who join a DR scheme may have been given false assurances by the promoter of the scheme and may have varying levels of awareness of the nature and risks of the scheme.’ 

In a wide ranging and detailed response, Harra also addressed criticism of the way HMRC staff have dealt with people affected by the loan charge issue.