This follows initial communications sent in 2025 advising those affected whether HMRC thought the disguised remuneration arrangements they used would be considered by the review of loan charge repayments.

HMRC has now started reviewing taxpayers’ arrangements and has started sending out letters from January 2026. In these letters, a taxpayers are given a named HMRC contact and are told ‘if and how their position is affected by the outcome of the review’.

In an update on the website, HMRC stated: ‘If a customer’s arrangements are covered by the recommendations of the review accepted by the government, then, at a later date, you should receive an invitation to settle at a reduced amount.’

The