This will be the only communication between HMRC and those caught up in the loan charge issue until the review is completed. It also appears that ongoing cases using multiple disguised remuneration, some outwith the review scope, will be able to delay their discussions.

To be precise, the HMRC briefing states: ‘Customers who would prefer to wait and finalise their tax positions for all their DR arrangements at the same time, can ask HMRC to pause this work until the review is complete.

‘Where a pause is requested for arrangements that will not be considered by the review, HMRC will not issue assessments nor close any enquiries to finalise the amounts due for these arrangements, unless there are important matters such as statutory or litigation deadlines we need to meet.’

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