Chaired by tax expert, Ray McCann, the review was announced last year with a brief to review the payment arrangements under the loan charge which caused so much anger among many of the affected taxpayers involved in disguised remuneration schemes.

Now the Treasury has published the review findings and has indicated it will go ahead with the recommendations on how to resolve this long festering problem set out in detail in the review, along with damning evidence about the use of the schemes over the years and aggressive actions of tax avoidance promoters and accountants.

The Treasury has been contacted for comment about their next steps.

The chancellor Rachel Reeves referenced the publication of the loan charge review by McCann near the end of her Budget speech on Wednesday, but did not indicate what action the government will take or whether the recommendations have been adopted.

The McCann review into the loan charge recommends that HMRC introduce a new settlement opportunity for those who used loan schemes, who have yet to settle their liability.

It also calls for the government to ‘suspend part of the liability’, and sets out how this could be achieved.

The report states: ‘Through the new settlement, individuals and HMRC can agree a reduced settlement amount, with the difference to their current Loan Charge liability suspended. If the terms of the suspension (eg, continued compliance) are met, the suspended amount should be written off after an agreed period of time.’

There is also a recommended method to calculate the suspended liability with a new settlement amount. The difference between that and the current Loan Charge liability is the suspended element.

The McCann review rcommends the following:

a) Unstack the tax years and calculate the tax owed in the years in which the income was earned;

 b) Suspend a proportion to account for promoters’ fees - suspend up to 10% (tapered by income) of gross scheme income per tax year to account for fees paid;

c) Suspend late payment interest;

d) Do not seek to apply penalties as standard; and

e) Do not collect inheritance tax through this settlement.

On more straightforward payment plans, allow payment plans of up to five years by default, and up to 10 years with HMRC approval.

The report recommends that 10 years should be the maximum length of payment plan, but there is a caveat: ‘If an individual cannot afford to pay the liability over 10 years, then, as a backstop, the remainder could be suspended.’

It also recommends that anyone facing the loan charge on state pension or universal credit should be treated as exceptional cases, where this is ‘no reasonable prospect of recovering much of the liability due to the economic circumstances’.

Where liabilities are settled with employers rather than the employees, HMRC should  not disallow any corporation tax deduction, and as with individuals, not apply penalties or inheritance tax (IHT), and ensure sufficient time to pay is available.

McCann also said promotors should be banned from providing additional tax services to avoid conflicts of interest, such as providing further tax advice or doing self assessment tax returns.

The huge rift between HMRC and loan charge victims has meant that neither party appear to be able to resolve this long running nightmare.

McCann called for better HMRC communication with loan charge community, saying HMRC should stop defaulting to template letters when writing to the affected taxpayers, for example.

The review recommends: ‘Improve HMRC correspondence with customers, by reducing the use of templates not more specific to the circumstance and considering certain clauses within contract settlements that have proven prohibitive to resolution.’

The Review considered close to 1,000 pieces of individual testimony submitted by those affected by the Loan Charge, shared either through the call for evidence or other engagement with the Review, those introduced by third party organisations, and impact statements shared with the All-Party Parliamentary Group on the Loan Charge.

The report also acknowledged the enormous amount of information shared with the review, noting: ‘The Review thanks those individuals who, having given written evidence, agreed to meet with the Review to discuss their experiences further. These conversations, that in many cases covered difficult topics, have been invaluable in understanding the extraordinary situation in which these individuals are currently placed.’

There was also some pressure put on professional bodies like ICAEW, CIOT and ICAS, among others, to ‘ensure that the limitation periods that they apply in relation to their disciplinary proceedings are realistic in the context of a tax scheme where failings in the quality of the advice or the activities of the adviser may not become known for a number of years after the scheme is used’.

From the mass of evidence collected from loan charge victims, one accountancy firm fell so far short of the professional standards expected that ‘the Review brought the behaviour of one firm to the attention of its professional body’. This simply highlights the widely held view that the professional bodies have not been as effective as they could have been in clamping down on egregious behaviour by certain accounting firms, which lured unsuspecting victims into disguised remuneration schemes and were paid handsome commissions for doing so.

The report also criticised the use of QC approval, in one instance identifying an instance where the barrister in question had signed off the scheme when he wasn’t even a QC.

McCann criticised these approvals, stating: ‘Some were inevitably not specific to the individual participant, instructed as they were by the scheme promoter, and so these were generic and often lacked the satisfactory consideration of the risks that participating in the scheme might expose the individual taxpayer to.’

From reading the review, it is clear that much of the evidence presented to the review was incredibly concerning.

‘The purpose of this Review was to identify the barriers to resolution for those who have yet to settle their Loan Charge and associated liabilities, and to propose ways in which those barriers could be overcome or reduced,’ the McCann review concluded.

‘Many such barriers have been identified: mistrust of HMRC, anger, confusion, and fear on the part of those involved; HMRC inflexibility; individuals continuing to place reliance on dubious advice given by scheme promoters; and, most commonly of all, individuals lacking the means to meet the large amounts required by HMRC, in part due to the unique retrospective effect of the Loan Charge.

‘HMRC inherited loan schemes from the Inland Revenue, with the resource requirements and costs now acting like an anchor against HMRC’s efforts to improve its customer service and compliance.

‘The recommendations are intended to allow those who want to settle, to settle.

‘They are also intended to allow HMRC to focus its efforts on the small minority of those involved, who, the Review has been told, are determined not to pay regardless of any new approach.’

McCann review, Independent Loan Charge Review 2025

Treasury confirms loan charge settlement will cost £365m | 27 Nov 2025

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