My client has received a 2019 assessment for a loan charge on a six-figure sum, the client simply has no way of paying this, what can I do?

This is not a technical note on the loan charge and tactics on how to make a challenge, it is rather a note on the reality that this debt may not go away.

It seems that HMRC has carried out a review of information they hold on the use disguised remuneration in the forms of loan that remain outstanding on 5 April 2019, where no settlement terms have been agreed with HMRC.

This resulted in a bulk issue of assessments in March and early April by HMRC to ensure they met the normal assessing time limit of four years.